Banner Life Insurance Company v. Moore

Background

Banner Life Insurance Company brought an interpleader action concerning proceeds under Dominic Sarkar’s life insurance policy. Interpleader is a procedure allowing a stakeholder facing competing claims to deposit the disputed property with the court and ask the court to determine the claimants’ rights.

The policy provided a $500,000 benefit. At Dominic Sarkar’s death, Maria Moore was listed as a primary beneficiary and her son, Marcus Moore, as a contingent beneficiary. The opinion states that Maria Moore was later convicted of Sarkar’s murder. It also states that California law bars a person who intentionally and feloniously kills another, as well as that person’s heirs, from receiving the deceased person’s life insurance benefit.

Elizabeth Sarkar, one of Dominic Sarkar’s daughters and a former contingent beneficiary, was among the competing claimants. Banner obtained permission to deposit the policy proceeds with the court and deposited $533,702.67 in the court registry. On August 14, 2025, the court entered default judgments against Maria and Marcus Moore. Elizabeth, Martha, and Mary Sarkar answered the amended complaint and remained as claimants.

Rulings

The court held that Banner’s interpleader action was proper under Federal Rule of Civil Procedure 22 and the federal interpleader statute, 28 U.S.C. § 1335, because the competing claims created a risk that Banner could face double liability. The court entered final judgment in Banner’s favor against the defendants on Banner’s interpleader claim, with an express finding of finality under Rule 54(b).

The order permanently and perpetually enjoins Maria Moore, Marcus Moore, Elizabeth Sarkar, Martha Sarkar, and Mary Sarkar from starting or pursuing any proceeding or claim against Banner in any court or other forum concerning the remaining proceeds of the policy. It also states that Banner has no further liability to those defendants, or to anyone claiming through them, for the policy proceeds; finds that Banner acted in good faith; excuses Banner from further participation; and directs the claimants to litigate their disputes without further involving Banner.

The court granted Banner’s request for $22,068.50 in attorneys’ fees and costs, to be deducted from the deposited funds. It also determined that the remaining proceeds should be distributed to Elizabeth, Martha, and Mary Sarkar and directed the clerk to disburse the funds, including accrued interest, to them through their counsel of record.