In re Millennium Multiple Employer Welfare Benefit Plan, 772 F.3d 634 (10th Cir. Nov. 13, 2014)
Participants and employers in multiple states sued the Millennium Multiple Employer Welfare Benefit Plan (the “Plan”) and multiple insurance companies that held their life insurance policies. The plaintiffs alleged tort claims and sought a declaratory judgment over ownership of their policies. The Plan declared Chapter 11 bankruptcy, and one insurance company sought to interplead the cash value of the policies it held into the court and enjoin the plaintiffs from prosecuting any state tort claims against it. The bankruptcy court granted the interpleader petition in part, but denied injunctive relief relating to the state tort claims. The Tenth Circuit affirmed, holding that interpleader relief does not permit the insurance company to shield itself from its tort liability or to limit its total liability in tort to the value of the policies.