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McLaughlin v. Hartford Life & Annuity Insurance Co.

United States District Court, District of Columbia

October 25, 2017

ELIZABETH MCLAUGHLIN, as personal representative of the estate of John Joseph McLaughlin, Plaintiff,



         From the nation's capital, a case brought by the estate of John Joseph McLaughlin, longtime moderator of the raucous political roundtable The McLaughlin Group.

         Question! On a scale from one to ten-with one being the chance of a Washington, D.C. professional sports team winning a championship this year and ten being absolute metaphysical certainty-how certain is the Court that Mr. McLaughlin, upon his divorce from his former wife Christina Vidal, intended for her to benefit from two life insurance annuities that he brought to the marriage? Any answer shy of nine would be . . . Wrong! Mr. McLaughlin did not wish his ex-wife to receive the annuity benefits. His estate is therefore the proper beneficiary and is entitled to a declaratory judgment saying so.

         I. Background

         In March 1996, before he married Ms. Vidal, Mr. McLaughlin designated her as the beneficiary of two annuity contracts that he purchased from Hartford Life & Annuity Insurance Company (“Hartford”) and Allianz Life Insurance Company (“Allianz”). Pl.'s Supp. Br. Ex. A. Mr. McLaughlin and Ms. Vidal executed a prenuptial property settlement agreement in 1997 and were married in June of that year. Compl. ¶ 9. The agreement provided for a lump-sum transfer of $1 million from Mr. McLaughlin to Ms. Vidal in the event of their divorce and indicated that the payment would settle all property rights arising out of their marriage. Id. ¶ 11. The couple divorced in 2010. In granting the divorce, the District of Columbia Superior Court found their prenuptial agreement fully enforceable and incorporated it into the judgment. Pl.'s Supp. Mem. Ex. C, at 2. Mr. McLaughlin died in Washington in August 2016. Id. ¶ 14. He was not survived by a spouse or children. Id.

         Plaintiff, who is Mr. McLaughlin's niece and the representative of his estate, filed this suit seeking a declaration that the estate is the sole beneficiary of the Hartford annuity.[1] She served Ms. Vidal personally with a summons and complaint on May 10. Ms. Vidal did not answer or otherwise respond to the complaint, and on June 26 the Clerk of the Court entered default against her. ECF No. 25. Plaintiff then moved for an entry of default judgment. ECF No. 26. On August 29, the Court issued a Minute Order to Show Cause why judgment should not be entered for Plaintiff and gave Ms. Vidal until September 20 to respond. That deadline passed over a month ago, and Ms. Vidal has not responded or sought more time to do so.

         In her motion for default judgment, Plaintiff relied exclusively on the common law “doctrine of implied revocation, ” which provides that a divorce and division of property generally revokes a former spouse's status as beneficiary of a will. Estate of Liles, 435 A.2d 379 (D.C. 1981). Plaintiff did not, however, cite authority supporting the application of that doctrine to annuities, life insurance policies, or other contract-based instruments, as opposed to wills. Noting that the District of Columbia Court of Appeals has expressly declined to extend the doctrine to contract-based instruments, [2] the Court by Order dated October 6, 2017 directed the parties to file supplemental briefing on two related issues: (1) Whether the doctrine of implied revocation operates to revoke a former spouse's status as beneficiary of an annuity, and (2) assuming that the doctrine does not apply to annuities, whether Plaintiff is entitled to the requested declaratory judgment for another reason. Plaintiff filed a supplemental brief and attached the prenuptial agreement and the judgment of divorce as exhibits.

         II. Legal Standard

         Default judgment is warranted “when the adversary process has been halted because of an essentially unresponsive party.” H.F. Livermore Corp. v. Aktiengesellschaft Gebruder Loepfe, 432 F.2d 689, 691 (D.C. Cir. 1970). Where a plaintiff has moved for default judgment, the Court must ensure that default was properly entered and, if so, decide whether the facts stated in the complaint, accepted as true, entitle the plaintiff to judgment in her favor. See Boland v. Elite Terrazzo Flooring, Inc., 763 F.Supp.2d 64, 67 (D.D.C. 2011).

         III. Analysis

         The Clerk properly entered default against Ms. Vidal, as she has yet to respond to the complaint, to Plaintiff's motion for default judgment, or to the Court's show cause order. See Fed.R.Civ.P. 55. And, having resolved the following issues, the Court finds that the facts stated in the complaint entitle Plaintiff to declaratory relief.

         Issue number one: Subject matter jurisdiction! Do the facts alleged establish it? Yes!

         For purposes of diversity jurisdiction, the representative of an estate is “deemed to be a citizen only of the same State as the decedent.” 28 U.S.C. § 1332(c)(2). At the time of his death, Mr. McLaughlin was a citizen of Washington, D.C. Compl. ¶ 2. Ms. Vidal is a citizen of Connecticut. Id. ¶ 5. The annuity contracts at issue each have a value greater than $75, 000. Id. ¶ 9. Thus, because the declaratory relief sought in the complaint would result in the disbursement of over $75, 000, and because Plaintiff and Ms. Vidal are citizens of different states, this Court has diversity jurisdiction over the case. 28 U.S.C. § 1332; see also, e.g., Thomas v. Metro. Life Ins. Co., 921 F.Supp. 810, 811 (D.D.C. 1996) (resolving issue of beneficiary designation through declaratory judgment).

         Next issue! Does this Court have personal jurisdiction over Ms. Vidal, a citizen of Connecticut? Certainly! District of Columbia law allows for specific personal jurisdiction over non-resident defendants “as to a claim for relief arising from the person's . . . transacting any business in the District of Columbia, ” D.C. Code § 13-423, and this standard is “coextensive with the Constitution's due process limit, ” First Chi. Int'l v. United Exch. Co., 836 F.2d 1375, 1377 (D.C. Cir. 1988). Thus, the Court may exercise specific jurisdiction if there is a sufficient relationship between the gravamen of the complaint-that Ms. Vidal is not the beneficiary of the annuities-and the District of Columbia, “such that the maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.'” Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). That is the case here. As explained below, the primary issue here is whether Mr. McLaughlin and Ms. Vidal's divorce-which resulted in the enforcement of a prenuptial agreement and a settlement of $1 million-revoked Ms. Vidal's status as beneficiary of the annuities. While Hartford is a Connecticut business and Allianz is from Minnesota, all other aspects of the transactions associated with the annuities occurred in the District of Columbia. Specifically: Mr. McLaughlin purchased the annuities and designated Ms. Vidal as their beneficiary. Compl. ¶ 9. Mr. McLaughlin and Ms. Vidal were married in Washington in 1997. Id. ¶ 6. While married, the couple lived together here. Id. In 2010, Ms. ...

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