## Facts

- United Benefit Life Insurance Company issued a $5,000 life insurance policy on the life of Csohan’s father.
- The insured died, and the parties did not dispute that the policy was in force and that the death had occurred.
- Csohan (plaintiff), a resident of San Diego, California, filed suit in the Court of Common Pleas for Cuyahoga County, Ohio, seeking payment of the $5,000 policy proceeds from United Benefit (defendant).
- After the Ohio suit was filed, competing claims within the family existed as to who was the proper beneficiary, and United Benefit asserted it was willing to pay the proceeds to the correct claimant but did not want to risk paying twice.
- About two months after the Ohio action began, United Benefit interpleaded in a California case pending in the Superior Court of California, Los Angeles County—litigation involving Betty Csohan (the decedent’s wife) and United of Omaha Insurance Company—aimed at resolving entitlement to the same insurance proceeds among rival claimants.
- Csohan moved in the Ohio action for a restraining order to stop United Benefit from continuing its participation in the California proceeding.
- United Benefit opposed the motion, arguing that California had jurisdiction over the competing family claimants, making California the better forum to resolve beneficiary status and protect the insurer from multiple liability.
- The Ohio trial court issued an injunction restraining United Benefit from continuing to participate in the California action.
- United Benefit appealed the injunction.

## Issues

1. May an Ohio court, in a first-filed action on a life insurance policy, enjoin the insurer (a party before the Ohio court) from continuing a later-filed California interpleader proceeding involving the same policy proceeds and competing claimants?

## Decision

- The Ohio Court of Appeals affirmed the trial court’s order enjoining United Benefit from continuing its participation in the California proceeding.
- The court concluded that, because United Benefit was subject to the Ohio court’s jurisdiction, the Ohio court could act in personam to restrain United Benefit’s conduct when necessary to protect the Ohio court’s prior jurisdiction over the dispute.

## Legal Principles

- A court of equity may enjoin a party subject to its jurisdiction from prosecuting or continuing litigation in another state when that foreign litigation would interfere with the court’s ability to resolve a matter already pending before it.
- An antisuit injunction operates in personam on the litigant, not as a direct command to the foreign court.
- The existence of a later interpleader action in another state does not automatically defeat the first court’s ability to proceed, even when the later action is framed as a means to avoid multiple liability.
- While respect for other states’ courts counsels caution, a court may restrain parallel out-of-state proceedings where doing so is necessary to prevent duplicative litigation and protect the first court’s control over the controversy before it.

## Conclusion

Csohan v. United Benefit Life Insurance Co. holds that an Ohio court hearing a first-filed action for life-insurance proceeds may enjoin the insurer, as a party within its jurisdiction, from continuing participation in a later California interpleader concerning the same fund and claimants, because the injunction acts on the party and serves to protect the Ohio court’s earlier-invoked jurisdiction over the dispute.


Csohan v. United Benefit Life Insurance Co., 200 N.E.2d 345 (1964)