S. Farm Bureau Life Ins. Co. v. Davis

2010 U.S. Dist. LEXIS 30036 (W.D. La. Mar. 26, 2010)



Statutory interpleader under 28 U.S.C. § 1335 confers on federal courts jurisdiction over certain interpleader claims. § 1335 declares that "district courts shall have original jurisdiction of any civil action of interpleader,"   as long as the amount in controversy equals $500 or more and the claimants are at least minimally diverse. 28 U.S.C. § 1335(a).


The plaintiff, Farm Bureau, filed this interpleader action naming as defendant, Ms. Davis and the unopened succession of her husband, Mr. Davis. At issue is a life insurance policy with a face value of $ 95,000.00 insuring the life of Mr. Davis. The named beneficiary of the policy, Ms. Davis, has been arrested  and charged with killing Mr. Davis. Pursuant to Louisiana law, a beneficiary of the life insurance policy cannot recover proceeds if she is deemed-to have been criminally responsible for the death, disablement, or injury of the insured, or judicially determined to have participated in the intentional, unjustified killing of the insured. Ms. Davis asserts that pursuant to 28 U.S.C.A. § 1335, there must be complete diversity between the defendant claimants, not between the stake holder (Farm Bureau) and the defendants. Farm Bureau asserts that the original complaint set forth, although, it did not specifically plead, general diversity jurisdiction as the basis for jurisdiction, as there was diversity between the plaintiff and the defendants, and an excess of $ 75,000 in controversy. The amended complaint specifically pleads general diversity as the basis for jurisdiction.


Did the court have jurisdiction over plaintiff's interpleader action?




An interpleader brought under Rule 22 must fall within one of the general statutory grants of federal jurisdiction. This may include diversity jurisdiction, provided that the complete diversity and amount in controversy requirements are met. In the instant case, the amount in controversy is over $ 75,000.00, and there is diversity between the plaintiff and the defendants. Because the requirements for general diversity jurisdiction are satisfied, the court has jurisdiction over plaintiff's interpleader action under Rule 22.

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