Metropolitan Life Insurance v. Mitchell, 2013 U.S. Dist. LEXIS 67837

Metropolitan Life Insurance Company filed an interpleader action on April 10, 2012, seeking to resolve competing claims to Plan benefits arising from the death of the Decedent.
The Plan provided $201,000 in Group Life Insurance benefits payable to a designated beneficiary; the Decedent’s March 2, 2004 designation named Mitchell as sole primary; Cooper later designated as sole primary on a March 10, 2011 application for life insurance conversion.
The Decedent died on June 24, 2011, while still eligible for the Group Life Insurance benefits, before the personal policy took effect; the benefits thus remained under the Plan.
Cooper submitted a claim for Plan Benefits and executed an assignment of proceeds; Mitchell claimed entitlement as the Decedent’s sole child and beneficiary.
The Plaintiff deposited the Plan Benefits with the Clerk of Court and sought dismissal with prejudice, discharge of liability for the Plaintiff and related parties, and a permanent injunction preventing further suits, while seeking attorneys’ fees (which were denied).
Mitchell and Cooper did not oppose the interpleader relief, and subsequent stipulations resolved related claims and payments prior to the Court’s decision.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether interpleader is appropriate under §1335	Plaintiff: requirements met—single fund, diverse claimants, deposit made, real fear of double liability.	Mitchell/Cooper did not oppose, but engaged in competing claims; no alternative basis asserted.	Yes, interpleader appropriate; requirements satisfied.
Whether the Plaintiff should be discharged from liability	Plaintiff seeks discharge after satisfying first-step requirements.	No separate liability exists against Plaintiff beyond interpleader needs.	Discharge granted; stakeholder released from further liability.
Whether a permanent injunction against further claims is warranted	Injunction prevents overlapping lawsuits and protects interpleader remedy.	Defendants not opposing, no contrary position stated.	Permanent injunction granted.
Whether attorneys’ fees and costs should be awarded	Fees justified as disinterested stakeholder; costs are appropriate in interpleader.	No special or extraordinary costs; ordinary course of business expenses should not be awarded as fees.	Fees and costs denied.

Fidelity Brokerage Servs., LLC v. Bank of China, 192 F.Supp.2d 173 (S.D.N.Y.2002) (two-step interpleader: determine propriety first, then adjudicate claims)
New York Life Ins. Co. v. Connecticut Development Authority, 700 F.2d 91 (2d Cir.1983) (stakeholder discharged if requirements satisfied)
Bankers Trust Co. v. Manufacturers Nat. Bank of Detroit, 139 F.R.D. 302 (S.D.N.Y.1991) (jurisdictional and procedural requirements for interpleader)
State Farm Fire & Casualty Co. v. Tashire, 386 U.S. 523 (1967) (minimal diversity suffices for interpleader)
Washington Elec. Coop., Inc. v. Paterson, Walke & Pratt, P.C., 985 F.2d 679 (2d Cir.1993) (minimal diversity standard in interpleader)
Mendez v. Teachers Ins. and Annuity Ass’n and College Ret. Equities Fund, 982 F.2d 783 (2d Cir.1992) (interpleader discharge when jurisdictional requirements met)
Travelers Indem. Co. v. Israel, 354 F.2d 488 (2d Cir.1965) (interpleader doctrine and consideration of fees)