New York City Health & Hospitals Corporation v. Ronald Hunt individually and as…

Background

New York City Health & Hospitals Corporation (HHC) filed this interpleader action concerning the distribution of the vested account balance in Dr. Daniel Hippolyte Hunt’s retirement plan. An interpleader action allows a party holding disputed funds to ask the court to determine the proper recipients. HHC was the administrator of the decedent’s 403(b) Non-ERISA Volume Submitter Plan.

HHC deposited the plan proceeds with the court registry. The court then granted HHC’s request for discharge and dismissal, which left the competing defendants to litigate entitlement to the proceeds. Stephanie Hunt-Guillaume, Desmond Hunt, Courtney Hunt, and Adrian Williams, referred to collectively as the “Cross-Claimants,” sought distribution under the plan documents. Ronald Hunt, acting without a lawyer, argued that the proceeds were estate property and should instead be distributed under the decedent’s last will and testament.

Motions and Report and Recommendation

The Cross-Claimants moved for summary judgment, which asks the court to rule because the material facts and governing law establish that one side is entitled to judgment. Ronald Hunt filed a cross-motion for summary judgment. The Cross-Claimants also sought sanctions, attorneys’ fees, and costs against Ronald Hunt in connection with their cross-claim.

Magistrate Judge Katharine H. Parker recommended that the Cross-Claimants’ summary-judgment motion be granted, Ronald Hunt’s cross-motion for summary judgment be denied, and the Cross-Claimants’ request for sanctions, attorneys’ fees, and costs be denied.

District Court’s Review and Ruling

Neither Ronald Hunt nor the Cross-Claimants filed objections to the Report and Recommendation by the applicable deadlines. The district court therefore reviewed the unobjected-to recommendations for clear error, meaning an obvious mistake in the record. Judge Rearden also reviewed the motions and the Report and Recommendation and found them well reasoned and supported by the facts and law.

The court adopted the Report and Recommendation in its entirety. It granted the Cross-Claimants’ motion for summary judgment, denied Ronald Hunt’s cross-motion for summary judgment, and denied the Cross-Claimants’ motion for summary judgment on their cross-claim for sanctions, attorneys’ fees, and costs. The Clerk of Court was directed to close the case.