Symetra Life Ins. Co. v. Rapid Settlements, Ltd., No. 13-20412 (5th Cir. 2014)
Annotate this CaseSymetra appealed the district court's refusal to award attorneys' fees under the Texas and Washington State Structured Settlement Protection Acts (SSPAs). Rapid cross appealed the district court's award of attorneys' fees as damages for tortious interference and the district court's permanent injunction, arguing that the injunction relies on an erroneous interpretation of the SSPAs. The court concluded that the district court erroneously held that Symetra could not recover any fees under the SSPAs where specific transfers were challenged throughout this litigation and Symetra can recover some portion of its fees related to some of those transfers. Therefore, remand is appropriate, but Symetra bears the burden of segregating fees and the district court retains discretion to deny Symetra's attorneys' fees request for failure to segregate. The court also concluded that the district court's award of fees incurred in state court with respect to one annuitant as damages for tortious interference under Texas law was proper where the natural and proximate cause of Rapid's conduct toward the annuitant was to drag Symetra into Indiana state court litigation. The district court's requirement that state court transfer orders also list first-refusal rights contravenes the SSPAs. However, the court found no error in the district court's analysis of first refusal rights under the SSPAs. Accordingly, the court affirmed in part, reversed in part, and remanded for further proceedings.
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