Judge Arthur Spatt
Former Cablevision employee William L. Mitchell Sr. (Decedent) obtained ERISA-governed group life through Metropolitan Life (MetLife) A March 2004 beneficiary form named defendant Mitchell the sole primary beneficiary of the group life benefits. Decedent subsequently converted $100,00 to a personal life policy. On March 10, 2011, he named defendant Cooper the sole primary beneficiary for personal life insurance benefits. Mitchell was designated contingent beneficiary. The court granted MetLife interpleader relief against Mitchell and Cooper on their competing benefits claims. it also discharged MetLife, Cablevision and the Cablevision Life Insurance Plan from liability. MetLife was a neutral stakeholder faced with competing claims to Plan benefits. However, the court denied MetLife’s motion for attorneys’ fees and costs. It deemed conflicting claims to policy proceeds an inevitable, normal risk of the insurance business and noted that an interpleader actionreliving the insurer of multiple lawsuits and leading to the insurer’s dischargeare brought primarily in an insurer’s own self-interest. In seeking interpleader MetLife did not incur any unique expenses exceeding the normal cost of doing business as an insurance company.
