Stonebridge Life Insurance v. Kissinger, 2015 U.S. Dist. LEXIS 19552

Stakeholder Stonebridge deposited $50,304 with the Court Registry pursuant to an interpleader action.
Competing claims to the Death Benefit were filed by Diane Latko (as executrix/creditor and as beneficiary) and Sherry Kissinger (daughter).
Policy history: JCPenney Life policy originally named Kissinger as beneficiary; 1993 change named Latko; divorce occurred in 2006; insured Randall Latko died in 2013.
Plaintiff sought interpleader relief, discharge from liability, and an award of attorney’s fees and costs; Latko opposed only the fee award.
Plaintiff complied with an order to deposit funds (Feb. 9, 2015).
Default judgments were entered against other insured’s children, who did not participate further.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is interpleader relief appropriate given multiple adverse claims to the fund?	Plaintiff argues two or more adverse claimants exist and fund is at risk.	Latko acknowledges competing claims but seeks exclusion of fee award; she does not oppose interpleader relief.	Yes; interpleader appropriate and stakeholder discharged.
Whether Plaintiff may recover attorney’s fees and costs from the deposited funds?	Plaintiff is a disinterested stakeholder who deposited funds and sought discharge.	Plaintiff’s conduct created confusion; fees should be denied.	Fees and costs may be awarded; plaintiff must file a separate fee application.
Did Plaintiff’s conduct cause the dispute over the proceeds?	No evidence showing Plaintiff caused the dispute; Kissinger’s claim preceded interpleader.	Plaintiff’s conduct allegedly provoked competing claims.	Court rejected the argument that Plaintiff caused the dispute; no automatic denial of fees.

NYLife Distrib., Inc. v. Adherence Group, Inc., 72 F.3d 371 (3d Cir.1995) (interpleader remedial purpose; efficiency in resolving multiple claims)
Prudential Ins. Co. of Am. v. Hovis, 553 F.3d 258 (3d Cir.2009) (discretion to award fees to disinterested stakeholder in interpleader)