Friday, December 6, 2013

Csohan v. United Benefit Life Insurance Co. case brief

Csohan v. United Benefit Life Insurance Co. case brief summary
200 N.E.2d 345 (1964)

Appellant insurer sought review of a decision by the Court of Common Pleas of Cuyahoga County (Ohio), which issued an injunction precluding the insurer from proceeding with a subsequently filed interpleader action against appellee beneficiary in another state.

The beneficiary, a California resident, brought an action against the insurer in Ohio to recover benefits under a life insurance policy. The insurer filed an interpleader action in California in which it asked that court to determine which of two claimants was entitled to the funds. The beneficiary filed a motion in the trial court for an injunction precluding the insurer from proceeding with the interpleader action. The trial court granted the injunction, and the insurer sought review.


  • The court reversed. 
  • The court found that full and complete justice could not have been granted in the Ohio action because the second claimant was not subject to the trial court's jurisdiction. 
  • The court stated that it was not inclined to sanction a course that would have exposed the insurer to the risk of having to pay the proceeds twice. 
  • The court noted that the insurer wished only to have the conflict determined in a court that had the power to decide which of the claimants was the proper beneficiary and thereby protect the insurer from potential double exposure. 
  • The court said it knew of no reason why the California court could not have resolved the merits of the action.

The court reversed an injunction that prohibited the insurer from proceeding with an interpleader action against the beneficiary in another state.

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