Narrative Opinion Summary
The Court of Appeals of Tennessee affirmed the trial court's decision to approve the transfer of structured settlement payment rights from the original payee to a new assignee, RSL Funding, LLC, in accordance with the Structured Settlement Protection Act (SSPA). The respondent, JG Wentworth Originations, LLC, opposed the transfer, claiming it violated previous court-approved transfers of payment rights to them. Despite Wentworth's objections and motion to intervene, the trial court found that the transfer complied with all statutory requirements and was in the best interest of the payee. The court further clarified Wentworth's role as a custodian for the unassigned payment portions, requiring them to remit these payments to RSL's assignee, Extended Holdings, Ltd. The appellate court conducted a de novo review, focusing on statutory interpretation and legislative intent, and concluded that prior court orders did not constitute 'applicable law' under the SSPA. The appeal was dismissed, affirming the trial court's order and assigning appellate costs to Wentworth, thereby upholding the structured settlement transfer and remanding the case for enforcement of the judgment.
Legal Issues Addressed
Best Interest Determination under SSPAsubscribe to see similar legal issues
Application: The transfer was deemed in Ms. Shanks’s best interest, fulfilling the requirements of the SSPA.
Reasoning: The court confirmed that the Order of Transfer was indeed in Ms. Shanks’s best interest, as required by law, and found no evidence contradicting the trial court's findings regarding the Transfer Agreement's compliance with the SSPA.
Collateral Attack on Prior Orderssubscribe to see similar legal issues
Application: Wentworth's argument that the transfer constituted a collateral attack on prior orders was dismissed due to waiver by not raising the issue earlier.
Reasoning: Wentworth argued that RSL's application for transfer constituted a collateral attack on prior orders but was deemed to have waived this argument by not raising it earlier.
Custodial Relationship in Structured Settlementssubscribe to see similar legal issues
Application: Wentworth's role in managing structured settlement payments was defined as custodial, requiring remittance to RSL's assignee.
Reasoning: A special custodial relationship exists where Wentworth acts as a servicer and custodian of the Wentworth Serviced Payments for Ms. Shanks and Assignee, without ownership rights.
Jurisdiction of Tennessee Circuit Courtssubscribe to see similar legal issues
Application: Tennessee circuit courts have nonexclusive jurisdiction over applications for structured settlement transfers under the SSPA.
Reasoning: Tennessee circuit courts have nonexclusive jurisdiction over applications for structured settlement transfers, and the transfer must not violate applicable laws, as defined by Tennessee Code Annotated sections 47-18-2603(1) and 2606.
Statutory Construction and Interpretationsubscribe to see similar legal issues
Application: The appellate court reviewed statutory language to determine that prior court orders do not constitute 'applicable law' under the SSPA, emphasizing legislative intent.
Reasoning: The principles of statutory construction emphasize the importance of legislative intent, the meaning of statutory language, and the avoidance of interpretations that create inconsistencies within the statute.
Structured Settlement Protection Act (SSPA) Compliancesubscribe to see similar legal issues
Application: The trial court approved the transfer of structured settlement payment rights, determining the transfer met all statutory requirements under the SSPA.
Reasoning: The trial court determined that the new transfer met all statutory requirements and found no error in the approval process.