Genworth Life Insurance Company of New York v. Andrews, 6:23-cv-06197

Genworth Life Insurance issued a $100,000 life insurance policy to Rawleigh Andrews, with his wife, Skavon Andrews, as the sole primary beneficiary and no contingent beneficiaries.
Rawleigh Andrews died on September 20, 2022, from a gunshot wound; Skavon Andrews was convicted of criminally negligent homicide in his death.
Other claimants include alleged heirs and grandchildren: Avery Muhammad (son), Tauron Smith (grandson), Anna Stesia Andrews (granddaughter), and minor Marcellus Andrews (grandson).
Genworth withheld the policy proceeds due to the ongoing homicide investigation and uncertainties regarding beneficiary eligibility.
Genworth filed an interpleader action under 28 U.S.C. § 1335, seeking to deposit the policy funds with the court and be discharged from further liability.
No defendants opposed Genworth’s motion to deposit funds and be discharged; Genworth moved for an injunction against related lawsuits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Genworth can deposit funds and be discharged from liability under § 2361	Genworth satisfied all interpleader requirements and faces adverse claims	No opposition filed	Court grants leave, permitting deposit & discharge
Whether an injunction against further litigation should issue	Injunction is necessary to prevent multiple lawsuits over same funds	No opposition filed	Court grants permanent injunction against related suits

Mendez v. Teachers Ins. & Annuity Ass'n & Coll. Ret. Equities Fund, 982 F.2d 783 (2d Cir. 1992) (sets out interpleader jurisdictional requirements)
Sotheby's, Inc. v. Garcia, 802 F. Supp. 1058 (S.D.N.Y. 1992) (court may issue injunction without following Rule 65 in interpleader)
Metro. Life Ins. Co., 966 F. Supp. 2d 101 (S.D.N.Y. 2013) (discharge of interpleader stakeholder when requirements are met)