Primerica Life Insurance Co. v. Reid, No. 21-1263 (8th Cir. 2022)
Annotate this CaseIla Reid appealed a district court’s summary judgment dismissal of her breach of contract claim against Primerica Life Insurance Company (“Primerica”). Reid brought her claim after Primerica filed an interpleader action to resolve competing claims to her late husband Garvin Reid’s life insurance beneficiary proceeds. She contended Primerica acted unfairly in multiple ways to create the controversy and thus the district court should not have permitted Primerica to use interpleader as a shield against her breach of contract claim. Finding no reversible error, the Eighth Circuit Court of Appeals affirmed the district court’s summary judgment order in favor of Primerica.
Court Description: [Grasz, Author, with Loken and Gruender, Circuit Judges] Civil case - Insurance. For the court's prior opinion in the case, see Primerica Life v. Woodall, 975 F.3d 697 (8th Cir. 2020). The district court did not err in determining that the unclean hands doctrine did not prevent Primerica from using interpleader as an equitable defense to defendant Reid's counterclaim for breach of contract; the undisputed facts showed Primerica and Reid's decedent shared fault which led to competing claims for the life insurance proceeds and the need to file the interpleader; the district court did not abuse its discretion in finding Primerica had not acted in bad faith and was entitled to summary judgment on the breach-of-contract counterclaim.
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