COURT OF APPEALS FOR THE EIGHTH CIRCUIT
Primerica Life Insurance Co. – Appellant
Versus
Ila Elaine Reid – Respondent
No. 21-1263 ___________________________
Primerica Life Insurance Company
Plaintiff - Appellee
v.
Betty Jo Woodall
Defendant
Ila Elaine Reid
Defendant - Appellant ____________
Appeal from United States District Court for the Eastern District of Arkansas ____________
Submitted: January 12, 2022 Filed: July 1, 2022 ____________ Before LOKEN, GRUENDER, and GRASZ, Circuit Judges. ____________ GRASZ, Circuit Judge. Ila Reid appeals the district court’s 1 summary judgment dismissal of her breach of contract claim against Primerica Life Insurance Company (“Primerica”). Ila brought her claim after Primerica filed an interpleader action to resolve competing claims to her late husband Garvin Reid’s life insurance beneficiary proceeds. She contends that Primerica acted unfairly in multiple ways to create the controversy and thus the district court should not have permitted Primerica to use interpleader as a shield against her breach of contract claim. We affirm the district court’s summary judgment order in favor of Primerica.
I. Background
This is the second time this appeal has come before us. See Primerica Life Ins. Co. v. Woodall, 975 F.3d 697, 698 (8th Cir. 2020). We need not recite all the facts here. A brief summary will suffice.
The genesis of the competing claims arose when Garvin tried to change via a “multipurpose change form” the beneficiary on his life insurance policy from Betty Jo Woodall, his ex-wife, to his new wife Ila. Garvin mistakenly completed the “Name Change” portion of the form in addition to the “Change Beneficiary” section, causing Primerica to request further information from Garvin. Garvin never responded. Following Garvin’s death, Primerica mailed claim forms to both Ila and Betty Jo. Both women submitted written claims of entitlement to the life insurance proceeds, after which Primerica brought an interpleader action under Federal Rule of Civil Procedure 22. Ila filed a counterclaim against Primerica for breach of contract, which was based on a theory that Primerica failed to pay the proceeds in a timely manner or perform its obligations in good faith.2
1 The Honorable Susan Webber Wright, United States District Judge for the Eastern District of Arkansas. 2 Ila does not argue that her claims are in any way independent of Primerica’s resolution of the controversy over the life insurance proceeds. See Lee v. W. Coast Life. Ins. Co., 688 F.3d 1004, 1011 (9th Cir. 2012) (finding “where the stakeholder -2- The district court awarded Ila the insurance proceeds by granting her motion for summary judgment as to the policy proceeds. However, the district court also granted Primerica’s motion for summary judgment, dismissing Ila’s counterclaim for breach of contract. On appeal, we remanded the case to the district court so that it could make a determination of fault as it related to whether Primerica had “unclean hands” and consequently could not take advantage of an interpleader. See Woodall, 975 F.3d at 700. On remand, the district court once again granted summary judgment in favor of Primerica.
II. Analysis
Ila argues the district court should have held that Primerica’s unclean hands
prevented it from using interpleader as a shield against liability. “We review the
district court’s decision to deny an equitable defense for an abuse of disc
Login now and unlock free premium legal research
Login to SupremeToday AI and access free legal analysis, AI highlights, and smart tools.
Login
now!
India’s Legal research and Law Firm App, Download now!
Copyright © 2023 Vikas Info Solution Pvt Ltd. All Rights Reserved.