Life Insurance And Interpleader

Life insurance lawyers will have potential new clients call up and say they have been served with legal papers.  These papers will state a life insurance company has death benefits they want to pay but the life insurance company is unsure who to pay the benefits to and so, they are interpleading the life insurance proceeds into the court, notifying people who have a possible interest in the benefits and letting the court and parties decide who is entitled to the proceeds.

A Western District, San Antonio Division opinion styled, Erika Sanchez v. Prudential, sheds some light on this subject.

Following the death of the insured, the OSGLI received three different SGLI Election and Certificates form the U.S. Army Reserves.  One certificate dated June4, 2011, designates the insured’s sisters, Middleton and Vial, as co-beneficiaries of the Death Benefit.  The June 2011 Certificate bears the insured’s electronic signature and indicates that it was received and/or accepted by the appropriate branch of service.  A second Certificate, dated August 6, 2011, designates Sanchez, the insured’s estranged wife, as a primary beneficiary of 75% of the Death Benefit and Middleton as the primary beneficiary of 25% of the Death Benefit.  The August 2011 Certificate also named Vial as a secondary beneficiary.  However, there is no indication that the August 2011 Certificate was submitted, received, and/or accepted by the applicable branch of service.  The final Certificate, dated September 30, 1975, designates Sanchez as the sole primary beneficiary of the Death Benefit.  The Sanchez Certificate bears what purports to be the Insured’s signature; however the Insured’s date of birth is listed as the date he signed the Sanchez Certificate.  Richard Teniente, the Insured’s Army Reserve Unit Administrator, is listed as the personnel clerk who allegedly completed the Sanchez Certificate.  However, Mr. Teniente states in a letter that he is unable to validate the Sanchez Certificate because it appears to have been altered.

On July 15, 2015, Sanchez submitted a claim for the Death Benefit.  On August 3, 2015, Vial submitted her claim for the Death Benefit.  On August 9, 2015, Middleton submitted her claim for the Death Benefit.

Federal Rule of Civil Procedure 22 permits an insurer “with claims that may expose it to double or multiple liability” to join those persons as defendants in a suit to determine each defendant’s rights.

This case discusses how an interpleader is properly filed in a Federal Court and how the Court determines whether or not the insurer is entitled to costs and attorney fees for filing the interpleader.