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New York Life Insurance v. Dunleavy

United States Supreme Court
241 U.S. 518 (1916)


In 1907, Boggs & Buhl (Boggs) obtained a personal judgment in Pennsylvania state court against Joseph Gould’s (Gould) (defendant) daughter, Effie Gould Dunleavy (Dunleavy) (plaintiff). At the time, Dunleavy was a Pennsylvania resident so the judgment against her was valid. In 1909, the surrender value of Gould’s life insurance policy with New York Life Insurance (NYLI) (defendant) became due for $2,479.70. Dunleavy alleged that the policy had been assigned to her in 1893. In November 1909, Boggs attempted to attach the life insurance money to its judgment against Dunleavy, summoning Gould and NYLI as garnishees. Gould answered, claiming full right to the life insurance money and that there had been no assignment to Dunleavy. NYLI answered by paying the disputed money into the court to be paid out to the correct party. NYLI also sought to interplead the parties to determine the correct recipient in one proceeding. Despite being given notice of the request for interpleader, Dunleavy, who had since moved to California, did not respond. Instead, Dunleavy brought this action in California in January 1910 to recover the insurance money. In the Pennsylvania case, the court found that there was no assignment and awarded the money to Gould. Meanwhile, in this case, the district court in California awarded the money to Dunleavy and the court of appeals affirmed. Gould appealed on the grounds that the Pennsylvania case was a bar to Dunleavy’s recovery in California because the Pennsylvania court had originally had jurisdiction over her.

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