Subject Matter Jurisdiction Not Found by District Court of New Jersey

Andrews v. Holloway, No. 95-1047, 2022 WL 6816758 (D.N.J. Oct. 11, 2022)

This case deals with subject matter jurisdiction regarding an estate matter in federal court.

The court referred to the long and circuitous history of the case, with the need for court intervention on numerous occasions.  The current application sought direction as to $12,000 in unclaimed settlement funds that counsel had held in escrow for the benefit of the estate of the decedent.  The decedent had been the plaintiff in the underlying action, which was commenced in 2008 and resolved a decade later.

Counsel was dealing with the decedent’s daughter and understood that she was the executor of the estate.  She signed the documents to settle the case.  However, counsel was later contacted by another daughter of the decedent, who disputed her sister’s competence to execute the settlement agreement, claimed to be the true representative of her father’s estate and demanded the settlement proceeds.

The court declined to reinsert itself into the decades-long litigation process and found it could not exercise subject matter jurisdiction on the facts presented since both daughters were residents of Arizona.  The court recognized counsel’s predicament and left open the prospect for him to file an interpleader action in a court of appropriate jurisdiction.