Unum Life Insurance Company of America v. Jansen

Background

Mary Jo Jansen held $84,000 in basic life insurance, $84,000 in basic accidental-death-and-dismemberment insurance, and $20,000 in supplemental life insurance through Unum Life Insurance Company of America. She died on February 8, 2019. The opinion states that she named Matthew Lynn Jansen as the 100% primary beneficiary and Bradley Jansen and E.J. as contingent beneficiaries, each with a 50% share.

Matthew was charged with Mary Jo Jansen’s murder, and the defendants made competing claims to the insurance benefits. Unum filed an interpleader complaint against Matthew, Bradley, and E.J. because the competing claims exposed Unum to the risk of multiple legal actions and liabilities.

Procedural History

Matthew was served with the summons and complaint on September 23, 2019, but did not respond. The clerk entered default against him in January 2020. Bradley had not been served as of the date of the order and had not appeared. E.J., a minor, was appointed a guardian ad litem, A&G Business Services, LLC, but E.J. had not appeared.

Unum moved for default judgment against Matthew. Under Rule 55 of the Federal Rules of Civil Procedure, the court explained that a default judgment treats the well-pleaded factual allegations against the defaulting party as admitted. The court also concluded that entering judgment against Matthew would not prejudice Bradley or E.J., even though claims against those two defendants had not been resolved.

Ruling

The court granted Unum Life Insurance Company of America’s Motion for Default Judgment against Matthew Lynn Jansen. It ordered that Matthew had no right to or interest in the life-insurance benefits payable under Unum Group Summary of Benefits Nos. 421073 and 421075, totaling $188,000. The order directed that judgment be entered accordingly.