Southern Farm Bureau Life Ins. Co. v. Davis
United States District Court for the Western District of Louisiana
2010 WL 1245024 (2010)
Southern Farm Bureau Life Insurance (Farm Bureau, plaintiff) issued a $95,000 life insurance policy naming Robyn Davis (defendant) as beneficiary, but after her husband's death, Davis was charged with killing him — and under Louisiana law, a beneficiary found criminally responsible for the insured's intentional, unjustified killing forfeits the policy proceeds, which then pass to the insured's estate absent a contingent beneficiary. Farm Bureau filed an interpleader action naming Davis and the estate as defendants to determine the rightful recipient, and Davis moved to dismiss for lack of subject matter jurisdiction.
Whether federal subject matter jurisdiction over interpleader actions must be based on 28 U.S.C. Section 1335, which requires an amount in controversy of $500 or more and only minimal diversity among claimants.