Farmers New World Life Insurance Co. v. Rees

Rosamaria Rees, insured under a $150,000 policy with Farmers New World Life Insurance (Farmers) (plaintiff), was murdered, and her husband Frank Rees (defendant) became a suspect; if he had feloniously killed her, her mother, as sole heir, would be entitled to the proceeds instead of Frank. Farmers held off paying either party during the investigation and filed an interpleader action, depositing the $150,000 with the court and naming Frank and Rosamaria's mother as competing claimants, even though the mother had not yet made an actual claim. The mother defaulted in the interpleader action, Frank was awarded the proceeds, and the trial court granted Farmers' request to recover its attorneys' fees for bringing the action out of the deposited funds; Frank appealed.