Hartford Life and Accident Insurance Company v. Fitzpatrick
1:14-cv-00812
M.D. Penn.Feb 5, 2018Background
- Hartford filed an interpleader action over $889,000 life insurance proceeds payable under a policy on Annemarie Fitzpatrick, who died June 6, 2012.
- Policy named husband Joseph B. Fitzpatrick III as primary beneficiary and the decedent’s two minor children (E.F. and R.F.) as contingent beneficiaries.
- Mr. Fitzpatrick was criminally charged, convicted of first-degree murder in the decedent’s death, sentenced to life, and after post-trial litigation his conviction was reinstated on appeal and the Pennsylvania Supreme Court denied review.
- Patrick and Bonnie Vassalotti are the court-recognized custodians of the decedent’s minor children and moved for summary judgment as custodians asserting the children are the rightful beneficiaries.
- No opposition to the Vassalottis’ summary judgment motion was filed; under local rules Mr. Fitzpatrick is deemed not to oppose.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a convicted killer may recover life insurance proceeds as primary beneficiary | Mr. Fitzpatrick asserted entitlement as the named primary beneficiary | Vassalotti: Pennsylvania’s slayer statute/Doctrine bars a slayer from receiving proceeds | Court: Slayer doctrine applies; Fitzpatrick forfeits recovery |
| Whether contingent beneficiaries (children) should receive proceeds | N/A (Hartford interpleaded funds and was later dismissed) | Vassalotti: As custodians, they claim the contingent-beneficiary interest for the minor children | Court: E.F. and R.F. are the rightful beneficiaries; award to Vassalottis as custodians granted |
| Whether summary judgment is appropriate given the record and lack of opposition | N/A | Vassalotti: No genuine dispute of material fact; conviction establishes slayer status; no opposing evidence | Court: Summary judgment granted for Vassalottis because no material factual dispute remains |
| Effect of procedural posture on entitlement to proceeds | Hartford sought interpleader; later dismissed | Vassalotti: Interpleader resolved by adjudicating competing claims; dismissal of Hartford does not affect outcome | Court: Interpleader resolved; appropriate order to distribute to contingent beneficiaries via custodians |
Key Cases Cited
- Sovereign Bank v. BJ’s Wholesale Club, Inc., 533 F.3d 162 (3d Cir.) (summary-judgment standard and materiality explained)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S.) (standard for genuine dispute at summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (U.S.) (party opposing summary judgment must point to specific evidence creating a genuine dispute)
- Guidotti v. Legal Helpers Debt Resolution, L.L.C., 716 F.3d 764 (3d Cir.) (summary-judgment principles and inferences for nonmoving party)
- Commonwealth v. Fitzpatrick, 159 A.3d 562 (Pa. Super. Ct.) (appellate decision reinstating guilty verdict)