Prudential Insurance Co. of America v. Athmer
United States Court of Appeals for the Seventh Circuit
178 F.3d 473 (1999)
Kevin Spann, an Illinois resident, owned and was the named insured of a Prudential Insurance Company of America (Prudential) (plaintiff) life-insurance policy. Kevin named his wife, Gina Spann, as the policy’s primary beneficiary, with the policy’s contingent beneficiaries being Gina’s natural son and Gina’s sister, Steven Hill and Betty Jo Pierce, respectively (defendants). Gina’s subsequent conviction in Georgia for murdering Kevin disqualified Gina as his beneficiary. DNA testing following Kevin’s death brought to light the hitherto unknown and unacknowledged existence of Kevin’s natural daughter, Chrystal Athmer (defendant). Athmer claimed the proceeds of Kevin’s life-insurance policy on the grounds that, as the murderer’s blood relatives, neither Hill nor Pierce should be allowed to substitute for Gina as the policy’s beneficiaries. Prudential filed an interpleader lawsuit to determine who was entitled to the policy proceeds. Applying Illinois law, a federal district court found that because Gina’s relatives had become estranged from Gina, Gina was unlikely ever to benefit even indirectly from the policy proceeds. The court awarded those proceeds to Hill and Pierce. Athmer appealed to the Seventh Circuit, which, as a threshold matter, determined that Illinois law, and not Georgia law, governed the case.
Rule of Law
Holding and Reasoning (Posner, C.J.)
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