Csohan v. United Benefit Life Insurance Co.

Facts

Csohan (Plaintiff), a resident of San Diego, California, filed an action in the Court of Common Pleas for Cuyahoga County in January 1984 against the United Benefit Life Insurance Company (Defendant). The suit sought a payment of $5,000 from a life insurance policy held by Plaintiff’s father. The parties did not dispute that the policy was in force and that the death had occurred. Two months after the Ohio suit was initiated, Defendant interpleaded in a suit between Betty Csohan, the decedent’s wife, and United of Omaha Insurance Company. The case was being heard in the Superior Court of California, Los Angeles County. In response to the interpleader, Plaintiff filed a motion for a restraining order in Ohio court, seeking to enjoin Defendant from continuing with its action in California. In response, Defendant argued that it was willing to pay whichever member of the Csohan family was the proper beneficiary of the insurance policy, but it was not willing to pay twice. Defendant further argued that while the Ohio court had jurisdiction in the instant case, the California courts had jurisdiction over both Csohans, making it important to litigate there. The Ohio court disagreed, and enjoined Defendant from continuing its participation in the California action. Defendant appealed.