New York Life Ins. Co. v. Dunlevy

241 U.S. 518 (1916)

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.