United States District Court, E.D. Michigan, Southern Division
OPINION & ORDER GRANTING MOTION TO RE-CALENDAR
FROM ADMINISTRATIVE CLOSING AND FOR THE DISTRIBUTION OF FUNDS
DEPOSITED WITH THE COURT (DKT. 30)
A. GOLDSMITH, UNITED STATES DISTRICT JUDGE
September 10, 2018, Defendant Scott S. Hadley filed an ex
parte motion to re-calendar this case and distribute funds
deposited with the Court (Dkt. 30). The Court entered an
order allowing any opposition to the relief requested in
Hadley's ex parte motion to be filed by March 21, 2019.
Defendant Timothy Beetschen filed a timely response (Dkt.
32); and Hadley filed a reply brief in support of his motion
(Dkt. 36). For the reasons discussed below, the motion is
15, 2015, Plaintiff Metropolitan Life Insurance Company
(“MetLife”) filed its complaint in interpleader
against defendants Beetschen and Hadley (Dkt. 1), believing
the two are rival claimants seeking entitlement to the life
insurance benefits payable by reason of the death of their
mother, Maxine Hadley. MetLife served as the claims
administrator for Maxine Hadley's life insurance
benefits. Beetschen, however, pleaded guilty to second degree
arson as well as involuntary manslaughter for causing his
mother's death. See Beetschen's Plea
Agreement, Ex. E to Compl. (Dkt. 1-6). MetLife could not
determine the proper beneficiary for the policy proceeds
because Michigan's Slayer Statute, Mich. Comp. Laws
§ 700.2803, may preclude Beetschen from receiving any of
the life insurance benefits. Compl. ¶ 12.
filed an action in Oakland County Probate Court for the
probate of the estate of Maxine Hadley and to determine the
applicability of Michigan's Slayer Statute to
Beetschen's actions. In light of the pending probate
court matter, the Court granted MetLife's motion to
deposit funds with the Court on December 30, 2015 (Dkt. 21).
On April 19, 2016, the probate court found that Beetschen was
subject to the Slayer Statute and not eligible to receive the
proceeds of Maxine Hadley's life insurance policy.
4/19/2016 Probate Court Opinion, Appendix A to Resp., at
PageID.254-255 (Dkt. 32-1). Beetschen appealed and the
parties stipulated to administratively close the present case
pending resolution of the probate case (Dkt. 29).
Michigan Court of Appeals affirmed the probate court. In
re Estate of Hadley, No. 332888, 2017 WL 6542682, at *6
(Mich. Ct. App. Dec. 21, 2017). The appellate court noted
that although the probate court's opinion was somewhat
“muddled” and said that Beetschen was
“criminally accountable, ” the opinion was not
clearly erroneous because the probate court was aware of and
applied the correct legal standard. Id. The Michigan
Supreme Court subsequently denied Beetschen's application
for leave to appeal. In re Estate of Hadley, 502
Mich. 879, 912 N.W.2d 556 (2018).
August 14, 2018, the probate court ordered, among other
things, that the proceeds of the MetLife policy held by this
Court be distributed to Scott Hadley, because Beetschen is
barred from receiving the proceeds of his mother's policy
by Michigan's Slayer Statute. 8/14/2018 Probate Order,
Ex. A to Mot., at PageID.218. Shortly thereafter, Hadley
filed the present motion.
argues that this Court should find that he is not barred from
receiving the proceeds of his mother's policy because the
state courts reached the wrong result. Resp. at 14. He
concludes with the following reasoning:
Thus, as none of the evidence cited by the probate court
proves intent, Appellant respectfully requests that this
Honorable Court find that the probate court did not cite
sufficient evidence that there was intent in this case, and
find that the slayer statute does not apply to Mr. Beetschen,
and that he is entitles [sic] to inherit as per his
Id. However, whether the state courts came to the
correct result is not a matter that can be resolved by this
Court. The Court must give full faith and credit to state
full faith and credit statute provides that “judicial
proceedings of any court of any such State, Territory or
Possession [of the United States] . . . shall have the same
full faith and credit in every court within the United
States.” 28 U.S.C. § 1738. This requires a federal
court to give full faith and credit to the judicial
proceedings of state courts. Kremer v. Chem. Constr.
Corp., 456 U.S. 461, 482 (1982) (citing Allen v.
McCurry, 449 U.S. 90, 96 (1980)). Section 1738
“directs a federal court to refer to the preclusion law
of the State in which judgment was rendered.”
Marrese v. Am. Acad. of Orthopaedic Surgeons, 470
U.S. 373, 380 (1985). In Michigan, “[r]es judicata bars
a subsequent action between the same parties when the
evidence or essential facts are identical.” Dart v.
Dart, 597 N.W.2d 82, 88 (Mich. 1999).
is no question that this action is between the same parties
and the essential facts are identical. Although MetLife
brought this as an interpleader action, it was dismissed from
the case on December 30, 2015 (Dkt. 22). What remains of this
matter is the dispute between Hadley and Beetschen, which is
the same dispute that was resolved in the probate court.
Having lost his case in the Michigan courts, he cannot now
seek a second bite of the apple in this Court when he would
be precluded from doing so in Michigan state courts.
Kremer, 456 U.S. 461, 482 (1982).
Hadley's motion to re-calendar case from administrative
closing and for the distribution of funds deposited with the
court (Dkt. 30) is GRANTED. It is ordered
that this case be reopened and that the $30, 548.70, plus any
applicable interest, constituting the remaining group life
insurance benefits payable under the Fiat Chrysler
Automobiles FCA U.S. LLC Group Life Insurance Plan by reason
of the death of Maxine Hadley be disbursed ...