Metropolitan Life Insurance Company v. Scott et al
Filing
13
ORDER & REASONS denying without prejudice 12 Motion for Summary Judgment. Signed by Judge Martin L.C. Feldman on 6/3/2015. (caa)
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF LOUISIANA
METROPOLITAN LIFE INSURANCE COMPANY
CIVIL ACTION
v.
NO. 15-362
LYNDA TORRY SCOTT, ET AL.
SECTION "F"
ORDER AND REASONS
Before the Court is defendant Terrell McMaster's motion for
summary judgment.
For the reasons that follow, the motion is
DENIED without prejudice.
Background
Cornelius Scott was killed by a "lethal stab wound to the
chest." Mr. Scott is survived by his widow, Lydia Torry Scott, and
his son, Terrell McMasters.
Before he died on October 13, 2012,
Mr. Scott worked for Laitram, L.L.C., an ERISA-regulated employee
welfare benefit plan sponsored by Laitram and funded by group life
insurance policies issued by Metropolitan Life Insurance Company.
At the time of his death, Mr. Scott was enrolled under the Plan for
life insurance and accidental death and dismemberment coverage
totaling $482,000.00.
MetLife filed a complaint in interpleader in this Court on
February 5, 2015, asserting that it cannot determine the proper
beneficiary or beneficiaries of the group life insurance policy it
1
issued and administers as claim fiduciary for Laitram.
That is,
although the latest beneficiary designation on file with the Plan
for Mr. Scott names Mrs. Scott as the sole primary beneficiary of
the life insurance benefits, and Mrs. Scott completed an affidavit
for the Plan benefits, MetLife alleges in its complaint Mrs. Scott
has
not
been
ruled
out
as
a
suspect
in
Mr.
Scott's
death.
Accordingly, MetLife cannot determine whether a court would find
that Mrs. Scott is disqualified from receiving the Plan benefits
based on federal common law and state laws that prohibit an
individual from receiving funds if that person is convicted in the
death of the insured. If Mrs. Scott is disqualified, then the Plan
benefits would be payable to Mr. McMasters under the Plan's
facility of payment provision.
Accordingly, MetLife filed this
interpleader action as a mere stakeholder that is ready, willing,
and able to pay the Plan benefits to whomever the Court determines
benefits should be paid.
Consistent with this, the Court granted
MetLife's motion to deposit funds into the registry of the Court on
February 11, 2015.
Mr. McMasters, pro se, now seeks summary relief in his favor
and against Mrs. Scott on the ground that Mrs. Scott is precluded
from inheriting his father's benefits because she murdered him.
I.
Federal Rule of Civil Procedure 56 instructs that summary
judgment is proper if the record discloses no genuine dispute as to
2
any material fact such that the moving party is entitled to
judgment as a matter of law.
No genuine dispute of fact exists if
the record taken as a whole could not lead a rational trier of fact
to find for the non-moving party.
See Matsushita Elec. Indus. Co.
v. Zenith Radio., 475 U.S. 574, 586 (1986).
A genuine dispute of
fact exists only "if the evidence is such that a reasonable jury
could return a verdict for the non-moving party."
Anderson v.
Liberty Lobby, Inc., 477 U.S. 242, 248 (1986).
II.
Mr. McMasters invokes, generally, the "Slayer Rule," which he
submits prohibits inheritance by a person who murders someone from
whom he or she stands to inherit.1
The Court finds that Mr.
McMasters' motion is premature. There is evidence in the record to
support Mr. McMasters' contention that Mrs. Scott is the only
suspect in the homicide of Cornelius Scott.2
However, he fails to
refer the Court to the fact of any conviction, or any case law
holding that Mrs. Scott is precluded from recovery as a mere
suspect, as opposed to having been convicted of murder. It appears
from a brief survey of the case literature that conviction triggers
forfeiture.
See, e.g., Metropolitan Life Ins. Co. v. White, 972
F.2d 122, (5th Cir. 1992)("The [final murder] conviction alone
1
Mr. McMasters does not suggest which law (state or
federal or, if state, which state's law) applies.
2
Mr. McMasters cites the police report.
3
triggers the forfeiture rule as a matter of [Texas] law and, in
addition, is conclusive as a matter of federal law").
Accordingly,
Mr.
McMasters'
motion
is
DENIED
without
prejudice. Mr. McMasters may re-file a motion for summary judgment
that can be supported by additional factual evidence, such as proof
of conviction, or if he can direct the Court to binding or
persuasive case law that holds that one suspected of murder is
disqualified from receiving the decedent's benefits.3
New Orleans, Louisiana, June 3, 2015
______________________________
MARTIN L. C. FELDMAN
UNITED STATES DISTRICT JUDGE
3
Of course, the other parties to this case may submit
appropriate papers informing the Court as to these issues.
4
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