MetLife Life & Annuity Co. of Connecticut v. Akpele

Docket: CIVIL ACTION FILE NO. 1:13-CV-3898-TWT

Court: District Court, N.D. Georgia; June 21, 2016; Federal District Court

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An interpleader action has been initiated regarding the Motion for Disbursement of Funds from the Court Registry by the AIE Surgical Practice, LLC Defined Benefit Plan. Dr. Ignatius Akpele founded AIE Surgical Practice, LLC in 2000 and established the Defined Benefit Plan in 2005, which the IRS approved as a tax-qualified pension plan. Dr. Akpele, as the sole trustee, applied for a whole life insurance policy worth $5,148,206 with Travelers Life, designating the Defined Benefit Plan as the owner and beneficiary. Initially, Uzo Akpele and their child were beneficiaries, but this designation was changed to the Plan during underwriting, which the Akpele Defendants dispute but acknowledge is required by the Plan documents.

The policy was issued with the Defined Benefit Plan as the beneficiary, and after MetLife acquired Travelers, the policy was reissued with identical terms. Dr. Akpele was diagnosed with terminal cancer in 2009 and passed away in 2010. Following his death, MetLife contacted his family regarding the claim, indicating that benefits were payable to the Plan's trustee. Despite attempts by the Akpele Defendants to claim the benefits, MetLife refused payment, stating they were not listed beneficiaries, leading MetLife to file an interpleader complaint and deposit the death benefits with interest.

The Trustee of the Plan has filed a Motion to Disburse Funds, while Defendant Herrera argues for the enforcement of a settlement agreement between the Estate and the Akpele Defendants. The Defined Benefit Plan stipulates that participants cannot alienate or assign their benefits, aligning with ERISA regulations that designate the Trustee as the sole beneficiary of the Plan's assets, which cannot be subjected to external claims.

Counsel for the Akpele Defendants lacked the authority to enter into a settlement agreement with Dr. Akpele’s Estate, leading to the conclusion that the funds held in the Court’s registry are to be disbursed to the AIE Surgical Practice, LLC Defined Benefit Plan. The Trustee's request for the disbursement of these funds has been granted, while Defendant Herrera's renewed motion to enforce the settlement has been denied. This ruling was made on June 20, 2016.