PHL Variable Insurance Company v. Lackie

Background

PHL issued a term life-insurance policy with a $100,000 death benefit insuring Carol L. Lackie. The judgment states that Daniel D. Lackie owned the policy and was its primary beneficiary, while Charissa D. Lackie was the contingent beneficiary. Carol L. Lackie died on November 25, 2018, and the death benefit became payable.

The judgment states that the amended death certificate identified the death as a homicide and that the death remained under investigation. PHL alleged that Daniel was being investigated as a person of interest and that, if he were determined to have intentionally and feloniously killed the insured, he would not be legally entitled to the benefit. PHL said it could not determine who was legally entitled to the benefit and feared exposure to multiple or double liability.

PHL brought an interpleader action. Interpleader is a procedure allowing a stakeholder that faces competing claims to ask the court to resolve the claims or allow the stakeholder to pay the disputed property as directed while being protected from multiple liability. The judgment states that PHL properly brought the action and served Daniel, individually and as trustee of the trust, and Charissa.

Agreement and ruling

The defendants represented that they had reached an agreement concerning payment of the death benefit, and the court incorporated that agreement into the judgment. They agreed that PHL would be discharged from liability to them concerning the policy, the death benefit, the insured’s death, the lawsuit, and their claims to the benefit, except as provided in the parties’ agreement. The defendants were restrained from bringing or prosecuting related proceedings against PHL in state court, federal court, or an administrative tribunal.

The court entered a judgment of discharge in interpleader in PHL’s favor. It dismissed the action and ordered that the death benefit be paid and distributed as agreed by the defendants in the attached distribution agreement. The parties agreed that PHL would receive $12,000 in attorney’s fees and costs from the death benefit; otherwise, each party would bear its own fees and costs concerning the stipulation, discharge judgment, dismissal, and distribution order.

Disposition

The court entered judgment of discharge in interpleader in favor of PHL, dismissed the action, ordered distribution of the policy death benefit under the defendants’ agreement, and awarded PHL $12,000 in attorney’s fees and costs from that benefit.