Carpenters Pension Trust Fund for Northern California v. Hernandez

Background

The Carpenters Pension Trust Fund for Northern California and the Carpenters Annuity Trust Fund for Northern California filed an interpleader action involving benefits belonging to Michael Sanchez Hernandez. An interpleader action allows a holder of disputed funds to ask the court to determine who is entitled to them. The Trust Funds alleged that they had no interest in the benefits other than paying them to the proper beneficiary. The dispute was between Marcellina Hernandez, Michael Hernandez’s mother, and Charlotte McKeague, identified as his girlfriend.

In November 2020, the court granted the Trust Funds’ motion for default judgment against McKeague and ordered the Trust Funds to deposit the pension and annuity checks with the court. The court then dismissed the Trust Funds from the case, leaving Hernandez’s cross-claim against McKeague.

Service and Default

Hernandez made four attempts to personally serve McKeague at an address in Fairfield, California. After learning that McKeague did not live there, Hernandez located an address associated with McKeague in La Grange, California. She made two unsuccessful service attempts there. On the third attempt, she left the summons and cross-claim with Jane Doe, a household member at least 18 years old, and mailed copies to McKeague at that address.

The court found that this substituted service complied with Federal Rule of Civil Procedure 4 and California law because Hernandez had shown reasonable diligence in attempting personal service and had complied with the requirements for leaving and mailing the documents. The Clerk entered McKeague’s default on March 30, 2021. McKeague did not oppose the motion for default judgment or appear at the hearing.

Default Judgment

The court applied the factors used to decide whether to enter default judgment, including potential prejudice, the merits and sufficiency of the claim, the amount at stake, the possibility of disputed facts, whether the default resulted from excusable neglect, and the policy favoring decisions on the merits. The court found that these factors favored judgment for Hernandez.

Because default had been entered, the court treated the cross-claim’s factual allegations as true except allegations concerning damages. Hernandez alleged that Michael Hernandez named her as beneficiary in May 2005, that she remained the beneficiary until his death in October 2018, and that McKeague submitted a fraudulent change-of-beneficiary form without Michael Hernandez’s knowledge or consent while he was unconscious, incapacitated, and close to death. The court found that these allegations sufficiently established Hernandez as the proper beneficiary.

Relief and Disposition

The court granted Hernandez’s motion for default judgment. It declared Hernandez the proper beneficiary of Michael Hernandez’s benefits and awarded her both the pension and annuity benefits. The Clerk was ordered to release the funds deposited by the Trust Funds, which the order identified as $76,882.32 and $59,625.01. The court ordered final judgment to be entered and the file closed. This order disposed of Docket No. 53.