Automated Summary
Key Facts
Shane LaFond, a former employee of Inalfa Roof Systems, Inc., died on July 12, 2025 after being diagnosed with brain cancer in May 2024 and suffering strokes on July 6, 2024. LaFond's mother Darla Holmun was originally named as the 100% beneficiary of his 401(k) Plan Benefits, but on July 11, 2025—while LaFond was in a coma—an online beneficiary designation change was made naming his partner Heidi Foster as the 100% beneficiary. Inalfa received competing claims from both parties and filed an interpleader complaint to determine the rightful beneficiary. Holmun answered the complaint, but Foster failed to respond, resulting in a clerk's entry of default on June 20, 2025. The court granted Inalfa's motion for default judgment against Foster, ruling she is not entitled to any share of the 401(k) Plan Benefits.
Deceased Name
Shane LaFond
Issues
- The court must determine whether default judgment should be entered against Defendant Heidi Foster who failed to answer Inalfa's interpleader complaint regarding LaFond's 401(k) Plan Benefits. Foster was properly served but did not file an answer, and a clerk's entry of default was entered against her on June 20, 2025.
- The court must determine if Heidi Foster, who changed the beneficiary designation online while Shane LaFond was in a coma on July 11, 2025, is entitled to the 401(k) Plan Benefits or if the original beneficiary Darla Holmun remains the proper recipient. Foster failed to respond to Inalfa's request for proof of legal authority to make the change.
Date of Death
2025 July 12
Holdings
In this interpleader action, the Court granted Plaintiff Inalfa Roof Systems, Inc.'s motion for default judgment against Defendant Heidi Foster. Foster failed to respond to the interpleader complaint regarding her claim to Shane LaFond's 401(k) Plan Benefits, despite being properly served. The Court determined that Foster forfeits any claim of entitlement to the judgment proceeds and is not entitled to share in the 401(k) Plan Benefits. Additionally, Plaintiff Inalfa and the ERISA-regulated 401(k) Profit Sharing Plan are discharged from further liability to Defendant Foster relating to the Plan Benefits at issue.
Remedies
- The court granted Plaintiff Inalfa's motion for default judgment against Defendant Heidi Foster, finding that Foster is not entitled to share in the judgment proceeds of the interpleader action.
- The court ordered that Plaintiff Inalfa and the ERISA-regulated 401(k) Profit Sharing Plan sponsored by Inalfa be discharged from further liability to Defendant Heidi Foster relating to Shane LaFond's 401(k) Plan Benefits at issue in the interpleader action.
Probate Status
Not a probate case; civil interpleader action to determine 401(k) Plan Benefits beneficiary
Legal Principles
District courts may enter default judgment against a party who has failed to plead or otherwise defend an action and against whom the Clerk of the Court has entered a default. In interpleader actions, the plaintiff must apply to the court for default judgment when not seeking a judgment for a sum certain. When a defendant is in default, well-pled factual allegations in the Complaint are taken as true, except those relating to damages. The court need not conduct an accounting, determine the amount of damages, establish the truth of any allegation by evidence, or investigate any other matter.
Precedent Name
- Metro. Life Ins. Co. v. Harbison
- New York Life Ins. Co. v. Scrimger
- Prudential Ins. Co. of Am. v. Amarante
- Metro Life Ins. Co. v. Skinner
- Ford Motor Co. v. Cross
- Unum Life Ins. Co. of Am. v. Lytle
Cited Statute
Federal Rules of Civil Procedure Rule 55
Judge Name
Susan K. DeClercq
Passage Text
- Thus, because Foster has not responded to Inalfa's complaint, default judgment will be entered against her. See Prudential Ins. Co. of Am. v. Amarante, No. 18-CV-13618, 2019 WL 1397247, at *2 (E.D. Mich. Mar. 28, 2019) (noting that when a named interpleader defendant fails to answer the interpleader complaint or assert a claim to the funds, default judgment is proper). Because default judgment will be entered against Foster for failing to answer, she 'forfeits any claim of entitlement that might have been asserted.'
- District courts may enter default judgment against a party who has 'failed to plead or otherwise defend' an action and against whom the Clerk of the Court has entered a default. See FED. R. CIV. P. 55(a), (b)(2); see also Ford Motor Co. v. Cross, 441 F. Supp. 2d 837, 848 (E.D. Mich. 2006) ('When a defendant is in default, the well pleaded factual allegations in the Complaint, except those relating to damages, are taken as true.')
- Accordingly, it is ORDERED that Inalfa's Motion for Default Judgment against Defendant Heidi Foster, ECF No. 15, is GRANTED. To that end, judgment is ENTERED in favor of Plaintiff Inalfa and against Defendant Heidi Foster. Defendant Heidi Foster is not entitled to any share of the judgment proceeds of the underlying interpleader action. Further, Plaintiff Inalfa and the ERISA-regulated 401(k) Profit Sharing Plan sponsored by Inalfa is discharged from further liability to Defendant Heidi Foster relating to Shane LaFond's 401(k) Plan Benefits at issue in this interpleader action. IT IS SO ORDERED.
Beneficiary Classes
- Other
- Heir-At-Law