Metropolitan Life Insurance Company v. Asbell
6:21-cv-00332-RAW
| E.D. Okla. | Feb 13, 2023Background
- Ronald H. Asbell (Decedent) participated in two group life plans (Union Pacific and C&SPR) insured by MetLife; total death benefits approximately $79,000.
- MetLife received three signed beneficiary designations: June 15, 2004 (wife primary, revocable trust contingent); July 3, 2019 (Hill, Poteet, Stewart each 25%, revoking prior); March 14, 2020 (Hill, Poteet, Stewart each 33.3%, revoking prior).
- Decedent died August 28, 2020; claims were filed by Hill, Poteet, and Stewart; Keith Asbell claimed the 2004 designation/trust controlled and alleged later changes were invalid due to Decedent’s alleged dementia.
- MetLife notified claimants it would seek interpleader after attempts to resolve the dispute; it filed this interpleader action and moved to deposit the plan proceeds and be dismissed.
- Defendants Hill, Poteet, and Stewart answered and did not oppose MetLife’s motion; Keith Asbell was served by publication and did not appear.
- The court granted MetLife’s motion to deposit funds and dismiss, awarded MetLife $10,367.50 in fees/costs from the fund, discharged MetLife, and entered default judgment against Keith Asbell (precluding his recovery).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether interpleader is appropriate and MetLife may deposit the proceeds and be discharged | MetLife faces multiple competing claims and seeks to deposit funds and be discharged as stakeholder | Claimants dispute beneficiary entitlements; Keith argued older 2004 designation controls due to Decedent's incapacity | Court: interpleader proper; MetLife may deposit funds and is discharged |
| Jurisdiction to adjudicate competing claims | Federal jurisdiction under ERISA and diversity (amount in controversy > $75,000) | No jurisdictional objection | Court: jurisdiction exists under federal statutes and rules |
| Entitlement to attorneys’ fees and costs from the deposited fund | MetLife requested reasonable fees/costs incurred after giving notice and attempting resolution | Claimants did not object to fee request | Court: awarded MetLife $10,367.50 to be paid from the fund |
| Effect of Keith Asbell’s failure to appear | MetLife/other claimants sought resolution; defendants moved for default against Keith | Keith did not appear after service by publication; earlier emailed objections but no response in court | Court: granted default judgment against Keith; he recovers none of the benefits |
Key Cases Cited
- State Farm Fire & Cas. Co. v. Tashire, 386 U.S. 523 (U.S. 1967) (interpleader protects stakeholder from multiple liability and litigation)
- In re Millennium Multiple Emp. Welfare Benefit Plan, 772 F.3d 634 (10th Cir. 2014) (interpleader resolves competing claims to a single fund in stakeholder’s control)
- LaMarche v. Metro. Life Ins. Co., 236 F. Supp. 2d 50 (D. Me. 2002) (interpleader prevents stakeholder from defending multiple actions)
- United States v. High Tech. Prods., Inc., 497 F.3d 637 (6th Cir. 2007) (interpleader proceedings proceed in two stages: stakeholder discharge and then determination of claimants’ rights)