Northern District of Texas Rules in Life Insurance Beneficiary Interpleader

Primerica v. Cruz, et al is a recent decision in a life insurance beneficiary interpleader case from the North District of Texas. The case involved a dispute over life insurance proceeds for a policy issued by Primerica to Patrick McClevland. The policy named Takeya Cruz as the primary beneficiary and Jennifer Mathis as the contingent beneficiary. McClevland died on September 8, 2020, and all three defendants, including Candice Exsentico, made separate claims on the policy proceeds.

Primerica filed for interpleader, stating that it had no interest in the proceeds other than fulfilling its contractual obligation and had no independent liability to any of the defendants. All three defendants filed answers claiming some or all of the $300,000 in policy proceeds. Cruz pleaded for declaratory judgment to the entire amount, while Exsentico and Mathis each filed counterclaims against Primerica.

Mathis filed a motion to stay the proceedings until representatives of McClevland's minor children have joined the case and had an opportunity to be heard. Exsentico and Chalene Clark, represented by the same counsel, filed a motion to intervene on behalf of the minor children, attaching a proposed complaint in intervention that included a claim for declaratory judgment and claims against Cruz. Cruz opposed both motions and submitted additional evidence.

Cruz filed a motion for summary judgment seeking a declaratory judgment that she is the primary and exclusive beneficiary of the policy proceeds and that the policy proceeds are her exclusive property. Neither Exsentico nor Mathis responded. The court found that the summary judgment record showed that Cruz was the exclusive primary beneficiary of the policy and that there was no evidence that McClevland changed the beneficiary before his death. Thus, the court granted Cruz's motion for summary judgment as to her declaratory judgment claim and denied Exsentico and Mathis's counterclaim for declaratory judgment as moot.

Intervenors filed a motion to intervene in the case to assert their interests in the Policy proceeds, but Cruz argued they had no interest in the property. The court found that the intervenors' claims for breach of fiduciary duty and unjust enrichment did not relate to the Policy and that allowing their complaint in intervention would unduly delay or prejudice the original parties in the case. The court denied the motion for permissive intervention.

For guidance on life insurance beneficiary interpleaders, contact lawyer J. Michael Young (800) 323-1857.