Unum Life Insurance Company of America v. McDonald
3:24-cv-05995
W.D. Wash.May 20, 2025Background
- Unum Life Insurance Company filed an interpleader action in December 2024 to resolve competing claims to life insurance proceeds among Adam McDonald, Beckie McDonald, and Weeks’ Funeral Homes.
- Adam McDonald filed a motion for summary judgment before the parties had conducted discovery.
- Beckie McDonald opposed the motion and sought relief under Federal Rule of Civil Procedure 56(d), arguing discovery was necessary to develop facts regarding beneficiary designation changes.
- The court previously set discovery deadlines for November 28, 2025 and a trial for April 2026, indicating the case was still in early procedural stages.
- Both sides asserted factual disputes concerning changes to the decedent’s insurance beneficiary, specifically regarding the role of Amplify Energy and documentation.
- The court ruled on ancillary motions, including Unum’s deposit of funds and the dismissal of certain counterclaims, but the central dispute over beneficiary status remained unresolved.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Premature summary judgment before discovery | Adam: No discovery needed; sufficient evidence to decide | Beckie: Requires discovery to oppose summary judgment | Court granted Beckie's request for 56(d) relief; struck Adam's motion without prejudice |
| Entitlement to beneficiary status | Adam: He is the named beneficiary | Beckie: Evidence may show beneficiary change to her | Court found discovery required before deciding this dispute |
| Appropriateness of 56(d) relief | Adam: Opposed 56(d) relief, arguing no essential facts missing | Beckie: Identified specific, relevant discovery needed | Court found timely, specific, and relevant 56(d) request; granted relief |
| Court’s discretion to defer summary judgment | Adam: Implied summary judgment appropriate now | Beckie: Requested denial without prejudice until after discovery | Court exercised discretion to defer ruling until after discovery |
Key Cases Cited
- Burlington N. Santa Fe R. Co. v. Assiniboine & Sioux Tribes of Fort Peck Reservation, 323 F.3d 767 (9th Cir. 2003) (explains Rule 56(d) allows denial of summary judgment to permit discovery)
- Price ex rel. Price v. W. Resources, Inc., 232 F.3d 779 (10th Cir. 2000) (summary judgment should be refused if nonmoving party lacks opportunity to discover essential information)
- Family Home & Fin. Ctr., Inc. v. Fed. Home Loan Mortg. Corp., 525 F.3d 822 (9th Cir. 2008) (requirements for granting Rule 56(d) motion)