State law
Rhode Island: Beneficiary Disputes and Interpleader Under Rhode Island Law
Rhode Island's federal court has refused interpleader fees to an insurer that picked a winner before it filed. It has also let children enforce a Family Court decree against an ERISA plan beneficiary.
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The Rhode Island federal court denied an insurer its fees because it had already decided the claim: "It decided that Ms. Hogan was not entitled to the Policy proceeds and only sought interpleader protection after Ms. Hogan asked a court to resolve her dispute with Jackson." (slip op. at 9).
A fee lesson from a cross-border divorce
In Hogan, the insured bought a $200,000 policy in 2000 naming his then-wife. After the divorce he moved to New York, and she stayed in Rhode Island. When he died in 2013, the insurer denied her claim by email, citing New York’s revocation-on-divorce statute, N.Y. EPTL 5-1.4, and said it would pay accordingly unless she produced a court order to the contrary within 30 days.1 She sued in Rhode Island state court. The insurer removed the case, counterclaimed for interpleader, and deposited $219,377.40.
The court discharged the insurer and enjoined further claims against it under 28 U.S.C. § 2361. It denied fees and costs, explaining that the insurer had taken a side before seeking the court’s protection.2 The page on attorney’s fees in interpleader collects similar rulings, and New York covers EPTL 5-1.4.
Children’s rights under a Family Court settlement
Drainville involved group life coverage under an employer plan. A Rhode Island Family Court property settlement required the insured to keep his children as beneficiaries. He later named his second wife. The children, adults by the time of suit, cross-claimed. The magistrate judge recommended that their constructive trust claim go forward: “Cross-Claim Plaintiffs have adequately pled a constructive trust claim even though their claim for unjust enrichment may not be sustainable.”3
The district judge adopted the recommendation on May 4, 2009 (Doc. 52). In a later order (Doc. 71, July 23, 2009), the court treated the Family Court decree as a qualified domestic relations order under ERISA and granted the children declaratory judgment. It denied fees at that stage as premature. Because the plan was governed by ERISA, federal law, not Rhode Island property law alone, shaped the final result. See federal programs and ERISA and ERISA post-distribution claims.
The slayer chapter
Chapter 33-1.1 of the General Laws, “Disposition of Property of Person Killed by Another,” defines “Slayer” as “any person who wilfully and unlawfully takes or procures to be taken the life of another.”4 See the slayer rule for how courts handle pending criminal cases.
Decisions
Hogan v. Jackson National Life Ins. Co. (D.R.I. 2015)
- Facts
- The insurer denied the former spouse's claim under New York law, then interpleaded after she sued.
- Holding
- Discharge and injunction granted; fees and costs denied (slip op. at 9).
- Why it matters
- Taking sides can cost the insurer its fees.
Opinion: GovInfo.
Metropolitan Life Ins. Co. v. Drainville (D.R.I. 2009)
- Facts
- A Family Court settlement required the insured to keep his children as beneficiaries; he named his second wife instead.
- Holding
- The constructive trust claim was adequately pleaded (slip op. at 16); later, the decree was treated as a QDRO.
- Why it matters
- Divorce settlement promises can be enforced against a later beneficiary.
Report and recommendation: GovInfo.
Related guides
Footnotes
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Hogan v. Jackson Nat’l Life Ins. Co., C.A. No. 14-340 S, slip op. at 2–3 (D.R.I. Oct. 30, 2015). GovInfo. ↩
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Hogan, slip op. at 9. ↩
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Metropolitan Life Ins. Co. v. Drainville, C.A. No. 07-427 ML, slip op. at 16 (D.R.I. Mar. 31, 2009) (report and recommendation), adopted (D.R.I. May 4, 2009). GovInfo. ↩
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R.I. Gen. Laws § 33-1.1-1(3). Rhode Island General Assembly. ↩