## Facts

- In 2011, Carlos Iglesias-Alvarez purchased two annuities from National Western Life Insurance Company (National Western), paying approximately $2.935 million in premiums.
- For the first annuity, Carlos designated his brother, Francisco Iglesias (Francisco), as the beneficiary.
- For the second annuity, Carlos designated Francisco as both the owner and the beneficiary.
- Carlos died in November 2011.
- After Carlos’s death, National Western paid Francisco the benefits on both annuities.
- Carlos’s widow, Damaris Maldonado-Vinas, and Carlos’s two sons (plaintiffs) sued National Western in the District of Puerto Rico.
- Plaintiffs alleged the annuities were null and void under Puerto Rico law and sought repayment of the purchase price/premiums paid by Carlos.
- National Western moved to dismiss under Fed. R. Civ. P. 12(b)(7), arguing Francisco was a required party under Rule 19(a) but could not be joined because he lived in Spain and was not subject to the court’s personal jurisdiction.
- National Western argued that proceeding without Francisco risked subjecting it to multiple or inconsistent obligations because another court might later determine Francisco could keep the annuity benefits already paid.

## Issues

1. Whether Francisco, the beneficiary (and owner of one annuity) who had already received the annuity proceeds, was a person “required to be joined if feasible” under Fed. R. Civ. P. 19(a) in plaintiffs’ suit against the insurer to declare the annuities void and recover the premiums.

## Decision

- The court denied National Western’s Rule 12(b)(7) motion to dismiss.
- The court held Francisco was not a required party under Rule 19(a) for purposes of adjudicating plaintiffs’ claims against National Western.
- Because the court concluded Rule 19(a) did not require Francisco’s joinder, it did not proceed to a Rule 19(b) indispensability analysis.

## Legal Principles

- Under Rule 12(b)(7), dismissal for failure to join a party depends on Rule 19’s framework.
- Rule 19(a) requires joinder of an absent person if, in that person’s absence, the court cannot accord complete relief among existing parties, or if the person claims an interest relating to the action and proceeding without the person may (i) impair or impede the person’s ability to protect that interest, or (ii) leave an existing party subject to a substantial risk of double, multiple, or otherwise inconsistent obligations.
- “Inconsistent obligations” under Rule 19(a)(1)(B)(ii) refers to conflicting legal duties imposed on a party, not merely the chance of later litigation or the possibility of different results in separate suits.
- When a plaintiff seeks relief only from the defendant already before the court (here, repayment by the insurer), the court may consider whether it can resolve the dispute between those parties without determining the absent beneficiary’s rights as between the beneficiary and the defendant.

## Conclusion

The district court allowed plaintiffs’ action against National Western to proceed without joining Francisco, ruling that the already-paid beneficiary was not a required party under Rule 19(a) and denying the insurer’s Rule 12(b)(7) motion to dismiss.


Maldonado-Vinas v. National Western Life Insurance Co., 303 F.R.D. 177 (2014)