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Maldonado-Vinas v. National Western Life Insurance Co.

United States District Court for the District of Puerto Rico
303 F.R.D. 177 (2014)


In 2011, Carlos Iglesias-Alvarez bought two annuities from National Western Life Insurance Company (National Western) (defendant). The first named Carlos’s brother, Francisco Iglesias, as the beneficiary. The second named Francisco as owner and beneficiary. In November 2011, Carlos died. National Western paid Francisco claim benefits for both annuities. Damaris Maldonado-Vinas, Carlos’s widow, and Carlos’s two sons (family members) (plaintiffs) sued National Western, alleging that both annuities were null and void and seeking repayment of Carlos’s purchase price. National Western filed a motion to dismiss, arguing that Francisco was a required party to the suit and that joinder of Francisco is unfeasible. Francisco was a resident of Spain and the court did not have personal jurisdiction over him. National Western argued, among other things, that voiding the annuities could subject it to inconsistent obligations if another court later found that Francisco did not have to return the annuity benefits already paid out.

Rule of Law


Holding and Reasoning (Besosa, J.)

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