Life insurer sought to interplead death benefit in light of conflicting claims to the benefit among various beneficiaries. One claimant interposed a counterclaim for negligence claiming the insurer failed to properly process the beneficiary designation forms. The Appellate Division rendered summary judgment dismissing the claims and directed the deposit of the benefit into court. The insurance underwriter had no contract with the beneficiaries and consequently no duty of care. The underwriter was also awarded counsel fees as a disinterested stakeholder.

One of the very few ERISA cases in which the Court awarded counsel fees the plan administrator incurred in defending a claim for disability benefits. Second Circuit affirmed District Court’s award of 50% of administrator’s counsel fees on the basis the claimant presented false testimony and the claim was presented in bad faith.

Claimant of death benefit under group life policy brought ERISA claim to recover benefit and counsel fees. At issue was whether the claimant’s failure to present evidence of decedent’s employment satisfactory to the plan administrator was a sufficient basis to grant summary judgment dismissing the claim. The plan obligated the claimant to present evidence of employment reasonably requested by the plan administrator. Claimant submitted 1099s but had no w-2 statements or employment contract with the decedent. Moreover decedent was not on employer’s medical insurance plan that was provided to employees. The court denied summary judgement and held a fact issue existed whether the request for specific documents to support the claim was reasonable and that the submission of 1099s was not conclusive on the issue of decedent’s employment status.