Southern Farm Bureau Life Ins. Co. v. Davis

Facts

Plaintiff filed this interpleader action naming Defendants as defendants to determine who should receive the proceeds of the life insurance policy. At issue is a life insurance policy with a face value of $ 95,000.00 insuring the life of Mr. Davis. The named beneficiary of the policy, Defendant Davis, was arrested  and charged with killing Mr. Davis. Pursuant to Louisiana law, a beneficiary of the life insurance policy couldn’t recover proceeds if she was deemed-to have been criminally responsible for the death, disablement, or injury of the insured, or judicially determined to have participated in the intentional, unjustified killing of the insured. If the primary beneficiary is disqualified, and there is no contingent beneficiary, the life insurance proceeds are to be paid to the estate of the insured. Plaintiff was a corporation with its principal place of business in Mississippi. Defendants were citizens of Louisiana. Defendant Davis asserted that pursuant to 28 U.S.C.A. § 1335, there must be complete diversity between defendant claimants, not between the stake holder (Farm Bureau) and the defendants. Plaintiff asserted that the original complaint set forth, although, it did not specifically plead, general diversity jurisdiction as the basis for jurisdiction, as there was diversity between Plaintiff and Defendants, and an excess of $ 75,000 in controversy. The amended complaint specifically pled general diversity as the basis for jurisdiction.