SHARON ELLIS v. NICKIESHA DALHOUSE

Background

Metropolitan Life Insurance Company (MetLife) filed an interpleader action, which is a case asking competing claimants to resolve their rights to money held by a neutral stakeholder. The dispute concerned $403,000 in life-insurance benefits payable after Devon Ellis’s death.

Sharon Ellis, Devon Ellis’s sister, was the sole beneficiary under a July 8, 2017 beneficiary designation. On April 16, 2018, Devon Ellis signed a new designation allocating 20% of the proceeds to Sharon Ellis, 45% to Nickiesha Dalhouse, and the remaining proceeds among Mary Morrow Ojeda, Vilmont Lindo, and Renee Richards.

MetLife deposited the disputed funds with the court and was dismissed as a party on May 22, 2020. Sharon Ellis had answered and asserted claims seeking to revoke or rescind the April 16, 2018 beneficiary-change form. She later settled her claims against Morrow Ojeda, Lindo, and Richards. The court dismissed those parties and distributed certain amounts under the settlement. The funds disputed between Ellis and Dalhouse remained with the court.

Ruling

Because MetLife and all of the cross-defendants except Dalhouse were no longer parties, Judge Barbara Moses directed the Clerk of Court to amend the caption to reflect the parties’ remaining litigation positions: Sharon Ellis as plaintiff and Nickiesha Dalhouse as defendant.

The order addressed only the caption. It did not decide the parties’ competing claims to the life-insurance proceeds or determine whether the beneficiary-change form should be revoked or rescinded.