Susan Cripps, Defendant-Cross-Claimant-Appellant v. Life Insurance Company of North America, Plaintiff-Cross-Defendant-Appellee

OVERVIEW ’

Appellant Susan Cripps (“Susan”) and appellee Cynthia Cripps (“Cynthia”) both lay claim to the life insurance proceeds from the death of John Cripps (“John”), to whom both were married at different times. Appellee Life Insurance Company of North America (“LICNA”) interpled Cynthia, Susan, and Susan’s three children in a suit to determine who should receive those proceeds. Cynthia in turn cross-claimed against Susan, asserting her right to the proceeds. When Susan failed to answer, Cynthia obtained a default judgment against her. Susan now appeals that judgment, and raises a host of procedural arguments. We believe the district court lacked subject matter jurisdiction over the interpleader action. Accordingly, we reverse and remand to the district court with instructions to dismiss the interpleader claim. We find, however, that under ERISA the district court had subject matter jurisdiction over Cynthia’s cross-claim and personal jurisdiction over Susan. We also'find that the default judgment against Susan is legally insupportable. Accordingly, we vacate the default judgment and remand to the district court for a determination of whether Cynthia is entitled to any of the…