NEW YORK LIFE INS. CO. V. DUNLEVY
241 U.S. 518 (1916)
NATURE OF THE CASE: This was a suit to recover the proceeds of a life insurance policy.
FACTS: Dunlevy (P) filed this suit in a California court on January 14, 1910, against the
New York Life Insurance Co. (D) and Gould (D1) to recover the surrender value of a life
insurance policy. Gould was P's father. P claimed that D1 had assigned her the proceeds. P
got a judgment for $2,479.70, the amount of the surrender value. The circuit court of
appeals affirmed the decision. D claimed that P was precluded from recovery by certain
judicial proceedings in Pennsylvania where the proceeds had been garnished and D1 had been
determined to be owner. In 1907, Boggs & Buhl recovered a personal judgment by default
against P in a Pennsylvania court. In November 1909, Boggs & Buhl attempted to attach the
proceeds from the insurance policy in order to satisfy their judgment. D and D1 were
summoned as garnishees. After suit had begun in California, D admitted that they owed the
proceeds to someone and attempted interpleader. D was allowed to pay the proceeds to the
court in Pennsylvania. P received notice of this action but did not appear on the
interpleader. P appeared at the trial in Pennsylvania. That court held that D1 had not
assigned the proceeds to P, and D1 was awarded the monies. P claimed that the interpleader
was invalid; no personal jurisdiction. D maintained that the Pennsylvania court had
jurisdiction over P; the right to the money had been determined in a garnishment proceeding
to satisfy a judgment against P. Because the Pennsylvania court had jurisdiction over P for
the first action, it also had jurisdiction over P to satisfy the judgment against her. D
appealed the California decision.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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