Am. Gen. Life Ins. Co. v. Hannah
| Decision Date | 11 April 2014 |
| Docket Number | CIVIL ACTION NO. 1:12-cv-00087-GHD-DAS |
| Court | U.S. District Court — Northern District of Mississippi |
| Parties | AMERICAN GENERAL LIFE INSURANCE COMPANY PLAINTIFF v. EMMA M. HANNAH; HEATHER NAKOLE HANNAH; LETOYA JA'KIA HANNAH; JAMEELA VERNAY HANNAH; and JASMINE KIARRA HANNAH, by and through her mother and general guardian, Janice H. Hannah DEFENDANTS |
The case sub judice is an interpleader action filed by Plaintiff American General Life Insurance Company ("Plaintiff"), pursuant to Rule 22 of the Federal Rules of Civil Procedure and 28 U.S.C. § 1335, to determine the rights of the defendants to life insurance policy proceeds. The interpleaded fund amounts to $250,000 plus interest. Presently before the Court are two motions: a motion for summary judgment [16] filed by Defendants Heather Nakole Hannah, LeToya Ja'Kia Hannah, Jameela Vernay Hannah, and Jasmine Kiarra Hannah, by and through her mother and general guardian, Janice H. Hannah (collectively, the "Other Defendants"), as well as a motion for judgment on the pleadings [23] filed by Defendant Emma M. Hannah ("Hannah"). Upon due consideration, the Court finds that both motions should be denied.
Apparently, at the time of his death, Winfred Lee Hannah (the "Decedent") had two life insurance policies. One life insurance policy was issued by Primerica Life Insurance Company in the amount of $55,000, by the terms of which the Decedent's wife, Hannah, was designatedprimary beneficiary and no contingent beneficiaries were named. See Winston Cnty. Ch. Ct. Final J. [16-17] at 2 ¶ 6. The second life insurance policy was issued by the Old Line Life Insurance Company of America, of which Plaintiff is the successor in interest, in the amount of $250,000, by the terms of which Hannah was designated primary beneficiary and "All Children of [the Decedent]" were listed as contingent beneficiaries. See Pl.'s Compl. [1] ¶¶ I, VIII; Old Line Life Ins. Policy No. MM0010249 [1] at 13; Policy Appl. [1] at 30.
Winston Cnty. Cir. Ct. Indictment [16-3] at 1. On December 11, 2002, Hannah's murder trial commenced. Before any witnesses were called, Hannah expressed her desire to enter a plea of guilty to the lesser included offense of manslaughter. Subsequently, the district attorney stated the factual basis of the charge:
[T]he State would prove at trial that [Hannah] . . . did willfully, unlawfully, feloniously[,] and without authority of law, kill and murder [the Decedent] in a manner that could have been considered murder or possibly manslaughter. We would prove at trial in this case that she did, in fact, throw a boiler of boiling wateron [the Decedent], which, in fact, resulted in his death approximately 21 days later.
Hannah's Plea Colloquy Tr. [16-15] at 8-9. This exchange followed:
Id. at 9. Accordingly, Hannah's trial resumed. After the first witness testified, Hannah withdrew her previous plea of not guilty and entered a plea of guilty to the lesser included offense of manslaughter. See id. at 10. The court stated that Hannah understood she would be accepting the same factual basis for her plea that she had previously rejected, and Hannah agreed. Id. at 10-11. The court accepted her plea to the lesser included charge, convicted her of manslaughter,1 and sentenced her to 20 years in the custody of the Mississippi Department of Corrections. Winston Cnty. Cir. Ct. Judgment [16-4] at 1.
Subsequently, Hannah challenged her manslaughter conviction. First, on December 11, 2002, she filed a motion for post-conviction relief in the Circuit Court of Winston County which the circuit court denied. See Hannah v. State, 943 So. 2d 51, 52 (Miss. Ct. App. 2006) [16-12] at 1. Second, Hannah appealed that denial to the Mississippi Court of Appeals. See id. The courtof appeals affirmed the decision of the circuit court, finding no merit to Hannah's arguments. See id. Upon review, the Mississippi Supreme Court reversed the judgments of the court of appeals and the circuit court and remanded Hannah's case to the circuit court for an evidentiary hearing on Hannah's claims as to assistance of counsel and the voluntariness of her guilty plea. See Miss. Sup. Ct. On Mot. for Reh'g [16-13] at 11. On remand, the circuit court held an evidentiary hearing, during which Hannah withdrew her motion for post-conviction relief. See Winston Cnty. Cir. Ct. Order Dismissing Mot. for Post-Conviction Relief [16-5] at 3. Then, in 2009, Emma filed a second petition for post-conviction relief in the circuit court, alleging newly discovered evidence on the involuntariness of the withdrawal of her first petition for postconviction relief. See Hannah v. State, 49 S. 3d 654, 655 (Miss. Ct. App. 2010) [16-6] at 1. The circuit court denied the motion as non-meritorious, and the Mississippi Court of Appeals affirmed that decision. See id. Finally, on November 13, 2007, Hannah filed a petition for a writ of habeas corpus pursuant to 28 U.S.C. § 2254 in federal district court. On June 12, 2009, Judge Michael P. Mills adopted the Magistrate Judge's report and recommendation denying Hannah's motion for post-conviction relief for failure to exhaust state remedies and further finding that Hannah "willingly, deliberately, knowingly[,] and with the advice of counsel terminated the state post-conviction action and agreed to accept her sentence." See Report & Recommendation [16-9] at 5; Final Judgment Adopting Report & Recommendation [16-10] at 1. Hannah did not appeal this ruling to the Fifth Circuit Court of Appeals. She has exhausted all avenues of postconviction relief and has now finished serving her sentence.
Approximately one month before Judge Mills entered his ruling on Hannah's § 2254 petition, Defendants Heather Nakole Hannah and LeToya Ja'Kia Hannah, two of the Decedent's children who were appointed and acting as co-administratrixes of the Decedent's estate, filed acomplaint in the Chancery Court of Winston County to determine the Decedent's heirs at law. See Winston Cnty. Ch. Ct. J. Adjudicating Heirs at Law [1] at 8. The chancery court ruled that the Decedent, who died intestate, had five heirs at law: his widow Hannah and his children, who are the Other Defendants in this case. See id. at 9.
As stated above, the Decedent had two life insurance policies. Only the Primerica policy came to light during the proceedings to probate the Decedent's estate, and in fact, the chancery court ruled that the Decedent's entire probate estate consisted of the Primerica policy. See Winston Cnty. Ch. Ct. Final J. [16-17] at 2 ¶ 6, 4 ¶ 11. In that proceeding, the Other Defendants challenged Hannah's claim to the Primerica policy proceeds based on Mississippi Code § 91-125 (the "Slayer Statute"), id. at 3 ¶ 8; the chancery court determined that the proceeds were not payable to Hannah, despite her being named the primary and sole beneficiary to the Primerica policy proceeds, see id. at 3 ¶¶ 8-9; the chancery court paid the Primerica policy proceeds to the Decedent's estate, id. at 3 ¶ 9; and based on the chancery court's approval of the parties' compromise settlement of all Hannah's claims against the estate, Hannah received one payment of $7,500 from the Primerica policy proceeds "in full satisfaction of the claims of [Hannah] against the [Decedent's Estate] and the [Primerica policy]," id. at 4-5 ¶ 14, 6 ¶ 4.
Apparently unbeknownst to the Other Defendants, the Decedent also had the subject policy with Old Line Life Insurance Company of America. On November 29, 2011, after her release from prison, Hannah submitted a proof of death claim form to Plaintiff, requesting a lump sum settlement check for the subject policy. See Proof of Death [1] at 35. On April 23, 2012, Plaintiff filed an interpleader complaint, wherein it alleged that Hannah and the Other Defendants had competing claims to the subject policy proceeds and it was unable to determine the respective rights of the defendants to the subject proceeds. See Pl.'s Compl. [1] ¶ XI.Hannah and the Other Defendants filed separate answers to the complaint. Plaintiff subsequently deposited the subject proceeds into the Court registry and, upon the parties' agreement, was dismissed from the case. See Agreed J. of Dismissal with Prejudice [47]. On October 17, 2012, the Other Defendants filed a motion for summary judgment [16]. On November 5, 2012, Hannah filed a motion for judgment on the pleadings [23].2 With this factual and procedural background in mind, the...
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