United States District Court, D. New Jersey
JUDITH L. HOCKNELL, Plaintiff,
METROPOLITAN LIFE INSURANCE COMPANY, Defendant.
L. MASTEN MICHAEL J. NAPUDA MASTEN AND RAY PENNSVILLE, N.J.
08070 On behalf of Plaintiff
F. KNEPPER MCELROY, DEUTSCH, MULVANEY & CARPENTER, LLC On
behalf of Defendant
L. HILLMAN, U.S.D.J.
an ERISA matter concerning the denial of life insurance
benefits to the decedent's niece who held her uncle's
power of attorney. Currently pending are the parties'
cross-motions for summary judgment. For the reasons expressed
below, Defendant's motion will be granted, and
Plaintiff's motion will be denied.
Judith L. Hocknell, is the niece of Douglas W. Saul, who held
a group term life insurance policy through Defendant,
Metropolitan Life Insurance Company (“MetLife”),
as part of his employment with Mannington Mills, Inc.
(“Mannington”). On June 3, 2015, Plaintiff
forwarded an insurance beneficiary designation form to
Mannington's human resources department naming herself as
the sole beneficiary of the MetLife policy because her uncle
was under hospice care and his life expectancy was short.
Plaintiff believed, apparently mistakenly, that the
beneficiary designation needed to be revised to remove as a
beneficiary Plaintiff's sister, who had died a year
before. (Docket No. 7-5 at 28-29.)
October 27, 2015, Saul passed away. There were several
miscommunications between Plaintiff, Mannington's human
resources department, and MetLife, as well as missing
documentation, including a page from Saul's durable power
of attorney. Eventually Plaintiff received a letter from
MetLife denying her claim for benefits on April 7, 2016.
denied Plaintiff's claim because it determined that the
durable power of attorney did not permit Plaintiff to change
the designation of beneficiary to herself. (Id.)
MetLife also determined that because Saul had no designated
beneficiaries, it was required to apply the Plan's Line
of Succession provision, which awarded benefits to Saul's
spouse or civil union partner, child, parent, or siblings,
and if no such persons survived him, the estate.
(Id.) MetLife denied benefits to Plaintiff under the
Line of Succession provision because she was Saul's niece
and did not qualify as a lineal heir. (Id. at 84.)
appealed that decision, arguing that the durable power of
attorney did allow her to designate herself as a
beneficiary. (Docket No. 7-5 at 85-87). She cited to
several provisions in the document, including Paragraph 1,
General Grant of Power, Paragraph 2, Powers of Collection and
Payment, Paragraph 3, Life Insurance, and Paragraph 25, Good
Faith Reliance. (Id.; see also Docket No.
7-5 at 56-65.)
denied her appeal, stating that the power of attorney
“may not be read to include the power to designate a
beneficiary of life insurance unless that power is
specifically listed on the executed form, ” and
“the Power of Attorney does not specifically state that
the Attorney-in-Fact has power to designate or change a life
insurance beneficiary.” (Docket No. 7-5 at 95.)
filed the instant suit against MetLife,  claiming that
MetLife illegally denied her claim for the life insurance
benefits because the durable power of attorney
clearly grants Plaintiff the power to designate herself as a
beneficiary, citing to Paragraph 1, the General Power
“to exercise or perform any act, power, duty, right, or
obligation whatsoever, ” and Paragraph 2, Power of
Collection and payment, “to forgive, request, demand,
sue for, recover, collect checks, drafts, accounts, deposits,
legacies, bequests, annuities and pensions.” (Docket
No. 7-5 at 111.)
parties have moved for summary judgment in their favor.
MetLife argues that under the arbitrary and capricious
standard of review that must be applied to its benefit
determinations under the Plan, its denial of Plaintiff's
claim was based on a reasonable interpretation of the Plan
and the governing documents. MetLife argues that a New Jersey
statute, N.J.S.A. 46:2B-8.13a, controls and precludes an
attorney-in-fact from gratuitously transferring property of
the principal to herself without express and specific
authority. Because MetLife determined that the durable power
of attorney did not provide Plaintiff with that authority,
MetLife argues that its denial of Plaintiff's claim to
benefits cannot be deemed arbitrary and capricious.
response, Plaintiff argues that Paragraph 20 in the durable
power of attorney, a “Gifts” provision which
allows the attorney-in-fact to make gifts to certain
enumerated classes of people, satisfies N.J.S.A. 46:2B-8.13a,
and therefore MetLife's denial of her claim was an abuse
Subject matter jurisdiction
removed Plaintiff's complaint from state court on the
basis that the Court has federal question subject matter
jurisdiction over this action pursuant to 28 U.S.C. §
1331, and specifically under the Employee Retirement Income
Security Act of 1974 (“ERISA”), 29 U.S.C. §
1001, et seq., as amended.
Standard for Cross-Motions for Summary Judgment
judgment is appropriate where the Court is satisfied that the
materials in the record, including depositions, documents,
electronically stored information, affidavits or
declarations, stipulations, admissions, or interrogatory
answers, demonstrate that there is no genuine issue as to any
material fact and that the moving party is entitled to a
judgment as a matter of law. Celotex Corp. v.
Catrett, 477 U.S. 317, 330 (1986); Fed.R.Civ.P. 56(a).
If review of cross-motions for summary judgment reveals no
genuine issue of material fact, then judgment may be entered
in favor of the party deserving of judgment in light of the
law and undisputed facts. See Iberia Foods Corp. v. Romeo
Jr., 150 F.3d 298, 302 (3d Cir. 1998) (citation
Standard of Review under ERISA
is no dispute that the Plan meets the test to qualify as an
ERISA plan. ERISA provides that a plan participant or
beneficiary may bring a suit “to recover benefits due
to him under the terms of his plan, to enforce his rights
under the terms of the plan, or to clarify his rights to
future benefits under the terms of the plan.” 29 U.S.C.
§ 1132(a)(1)(B). The statute, however, does not specify
a standard of review ...