United States District Court, N.D. Alabama, Northwestern Division
K. KALLON UNITED STATES DISTRICT JUDGE
before his mother died, Aaron Patterson called Metropolitan
Life Insurance Company to request another copy of his
mother's life insurance policy. MetLife sent an
“Acknowledgment of Insurance, ” which incorrectly
stated the face value of the policy as $250, 000, when the
correct value was $25, 000. In light of Patterson's
belief that MetLife is bound by its mistake and should pay
$250, 000 instead of the actual face value, Patterson filed
this lawsuit, alleging breach of contract and bad
faith. Doc. 1. The parties filed motions for
summary judgment, which are fully briefed and ripe for
consideration. Docs. 20; 21; 22; 23; 24; 26; 27; 28; 29.
After reading the briefs, viewing the evidence, and
considering the relevant law, the court grants summary
judgment for MetLife.
LEGAL STANDARD FOR SUMMARY JUDGMENT
Rule 56(a) of the Federal Rules of Civil Procedure, summary
judgment is proper “if the movant shows that there is
no genuine dispute as to any material fact and the movant is
entitled to judgment as a matter of law.” Fed.R.Civ.P.
56. “Rule 56 mandates the entry of summary judgment,
after adequate time for discovery and upon motion, against a
party who fails to make a showing sufficient to establish the
existence of an element essential to that party's case,
and on which that party will bear the burden of proof at
trial.” Celotex Corp. v. Catrett, 477 U.S.
317, 322 (1986) (alteration in original). The moving party
bears the initial burden of proving the absence of a genuine
issue of material fact. Id. at 323. The burden then
shifts to the nonmoving party, who is required to “go
beyond the pleadings” to establish that there is a
“genuine issue for trial.” Id. at 324
(internal quotations omitted). A dispute about a material
fact is genuine “if the evidence is such that a
reasonable jury could return a verdict for the nonmoving
party.” Anderson v. Liberty Lobby, Inc., 477
U.S. 242, 248 (1986).
summary judgment, the court must construe the evidence and
all reasonable inferences arising from it in the light most
favorable to the non-moving party. Adickes v. S. H. Kress
& Co., 398 U.S. 144, 157 (1970); see also
Anderson, 477 U.S. at 255. Any factual disputes will be
resolved in the non-moving party's favor when sufficient
competent evidence supports the non-moving party's
version of the disputed facts. See Pace v.
Capobianco, 283 F.3d 1275, 1276, 1278 (11th Cir. 2002).
However, “mere conclusions and unsupported factual
allegations are legally insufficient to defeat a summary
judgment motion.” Ellis v. England, 432 F.3d
1321, 1326 (11th Cir. 2005) (per curiam) (citing Bald
Mountain Park, Ltd. v. Oliver, 863 F.2d 1560, 1563 (11th
Cir. 1989)). Moreover, “[a] mere ‘scintilla'
of evidence supporting the opposing party's position will
not suffice; there must be enough of a showing that the jury
could reasonably find for that party.” Walker v.
Darby, 911 F.2d 1573, 1577 (11th Cir. 1990) (citing
Anderson, 477 U.S. at 252)). The standards governing
cross-motions for summary judgment are the same, although the
court must construe the motions independently, viewing the
evidence presented by each moving party in the light most
favorable to the non-movant. See U.S. v. Oakley, 744
F.2d 1553, 1555 (11th Cir. 1984).
Patterson purchased a life insurance policy from MetLife with
a face value of $25, 000, naming her son Aaron Patterson as
the lone beneficiary. Doc. 21-1 at 6-35. The policy states
that “[t]his policy includes any riders and, with the
application attached when the policy is issued, makes up the
entire contract. . . . No statement will be used to contest
the policy unless it appears in the application.” Doc.
21-1 at 18. After obtaining the policy, Gail Patterson
consistently paid the monthly premiums until her death in
September 2015. Doc. 21-1 at 37-41. Sometime before her
death, her health gradually deteriorated, and Aaron Patterson
began handling her affairs. Doc. 24-1 at 9.
Patterson knew that his mother had a life insurance policy
with MetLife, but had never seen the policy and did not know
the face amount of the coverage. Doc. 26 at 4-5. On March 9,
2015, around the time his mother entered a nursing home, he
called MetLife to request a copy of the policy. Docs. 21-2 at
2; 21-4 at 9. One of MetLife's customer service
representatives, Lane Wiley, told Patterson that “what
we normally do is send out an Acknowledgement of Insurance
(“AOI”), which is a legal document providing the
policy information. For an exact duplicate of the entire
policy, there is a 25 dollar fee.” Doc. 21-2 at 2.
Patterson declined to pay the fee to receive the exact
duplicate, so that same day MetLife mailed to Gail Patterson
the one-page AOI, which incorrectly listed the face amount of
the policy as $250, 000. Docs. 21-2 at 2-3; 21-1 at 43.
cover letter accompanying the AOI reads: “We are
enclosing the Acknowledgment of Insurance you requested. The
acknowledgment serves the same legal purpose as the original
life insurance policy.” Doc. 24-26 at 8. The AOI states
that “[t]he original Policy, together with the
application upon which it was based, is the entire contract
between the Company and the Owner” and that the AOI is
only “a brief description of the Policy.” Doc.
21-1 at 43. The AOI also explains that “[a]ny
additional benefits contained in the Policy are not described
here” and that “[f]urther details about the
policy and benefits will be furnished upon request.”
Doc. 21-1 at 43.
his mother's death, Patterson called MetLife to file a
claim. Docs. 1-1 at 3; 21-4 at 2-3. When the MetLife
representative indicated that the estimated benefit was
approximately $30, 000-i.e. the $25, 000 face value plus the
yearly dividends, as authorized by the policy, doc. 21-4 at
3-Patterson responded, “[t]hat's what I was
wondering because on this piece of paper that we received
March 9th, 2015 . . . has the face amount of insurance [as]
$250, 000.” Doc. 21-4 at 3. The MetLife representative
explained that this figure was a mistake and that “[the
representative] just added another zero. . . . Or the decimal
is missing or out of place. . . . $25, 000 is the face
amount.” Docs. 21-1 at 14; 21-4 at 3. Patterson said
“Okay, ” and the call concluded shortly
thereafter. Doc. 21-4 at 3.
subsequently sent Patterson a letter approving his claim and
a check for $30, 030.66. Doc. 21-1 at 53. The letter noted
that the AOI had “incorrectly listed the policy face
amount” and that the correct amount was $25, 000. Doc.
21-1 at 51-53. MetLife included with the letter the annual
policy statements for the previous five years it had sent to
Gail Patterson, which all showed the face value as $25, 000.
Docs. 21-1 at 45, 53. Patterson subsequently filed this
lawsuit seeking to recover the full amount referenced in the
AOI. Doc. 1.
are no material facts dispute in this case. Therefore, the
court must decide which party is entitled to judgment as a
matter of law. Fed.R.Civ.P. 56. Because this matter is before
the court based on diversity jurisdiction, the court applies
Alabama's substantive law to each claim. Erie R. Co.
v. Tompkins, 304 U.S. 64, 78 (1938).