Filed: Jul. 11, 2016
Latest Update: Jul. 11, 2016
Summary: MEMORANDUM OPINION DEBORAH K. CHASANOW , District Judge . Presently pending and ready for resolution in this interpleader action is a motion for judgment on the pleadings or, in the alternative, for summary judgment filed by Plaintiff Mary Eastham. (ECF No. 32). The court now rules, no hearing being deemed necessary. Local Rule 105.6. For the following reasons, Plaintiff's motion will be granted. A more complete factual and procedural history of this action may be found in a prior memorand
Summary: MEMORANDUM OPINION DEBORAH K. CHASANOW , District Judge . Presently pending and ready for resolution in this interpleader action is a motion for judgment on the pleadings or, in the alternative, for summary judgment filed by Plaintiff Mary Eastham. (ECF No. 32). The court now rules, no hearing being deemed necessary. Local Rule 105.6. For the following reasons, Plaintiff's motion will be granted. A more complete factual and procedural history of this action may be found in a prior memorandu..
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MEMORANDUM OPINION
DEBORAH K. CHASANOW, District Judge.
Presently pending and ready for resolution in this interpleader action is a motion for judgment on the pleadings or, in the alternative, for summary judgment filed by Plaintiff Mary Eastham. (ECF No. 32). The court now rules, no hearing being deemed necessary. Local Rule 105.6. For the following reasons, Plaintiff's motion will be granted.
A more complete factual and procedural history of this action may be found in a prior memorandum opinion. (See ECF No. 30, at 1-5). In the prior opinion and accompanying order, the undersigned directed Wells Fargo Bank, N.A. ("Wells Fargo") to deposit with the clerk a check in the amount of $1,033,277.13 (the "disputed funds"), at which point Wells Fargo would be discharged from further liability and dismissed. (ECF No. 31 ¶¶ 2, 5). The remaining parties were realigned: Ms. Eastham is now the plaintiff and Todd Eastham, the Eastham Family Trust, Barbara Abramson, and State Farm Investment Management Corporation ("State Farm") are now defendants. (Id. ¶ 7). On May 19, 2016, the clerk received a check from Wells Fargo for the aforementioned amount and deposited the disputed funds into the registry of this court. (See ECF No. 33).
On May 19, Ms. Eastham filed the pending motion requesting that the court release the deposited funds to her. According to Ms. Eastham, Ms. Abramson and State Farm consent to the relief requested. Defendants Todd Eastham and the Eastham Family Trust have defaulted. (ECF No. 31 ¶ 8). No other party has filed a response to the pending motion, and the time to do so has expired.
Fed.R.Civ.P. 12(c) provides: "[a]fter the pleadings are closed — but early enough not to delay trial — a party may move for judgment on the pleadings."
The standard for resolving a motion pursuant to Rule 12(c) depends on the nature of the relief being sought.. . . In some situations, the standard for a Rule 12(c) motion on the pleadings is identical to the standard for summary judgment motions. 5C Wright & Miller, Federal Practice & Procedure § 1369 ("Both the summary judgment procedure and the motion for judgment on the pleadings are concerned with the substance of the parties' claims and defenses and are directed towards a final judgment on the merits."). [This] rubric is . . . appropriate where the moving party seeks affirmative relief on the basis of the pleadings and not merely a dismissal of claims brought against it.
The key distinction between a Rule 12(c) motion and a Rule 56 motion is that the court may not consider facts outside the pleadings under Rule 12(c). Motions on the pleadings can be used to obtain declaratory judgments where the parties' only dispute is the proper interpretation of contractual terms.
Geoghegan v. Grant, No. DKC-10-1137, 2011 WL 673779, at *3 (D.Md. Feb. 17, 2011) (citations omitted); see also CX Reinsurance Co. Ltd. v. Camden Mgmt. Servs., LLC, No. WMN-14-180, 2014 WL 5510914 (D.Md. Oct. 30, 2014) (granting a plaintiff's motion for judgment on the pleadings). Here, Ms. Eastham has not submitted any evidence to support her claim to the disputed funds, instead relying on factual assertions in the pleadings themselves. As such, her motion will be treated as a motion for judgment on the pleadings, and she is entitled to judgment if no other pleading contests her claim to the disputed funds. See Geoghegan, 2011 WL 673779, at *5 (noting that the "the standard is the same whether construed as a motion for judgment on the pleadings or a motion for summary judgment, namely whether there are any genuine disputes of material fact so that the case can be decided as a matter of law").
Here, no other pleading contests the fact that Ms. Eastham is entitled to the disputed funds. Ms. Eastham's answer asserts that it is undisputed that only she has an interest in the disputed funds. (ECF No. 24 at 2). Ms. Abramson disclaims any interest in the disputed funds in her answer. (ECF No. 20, at 1). Similarly, State Farm asserts in its answer that it has not made any claim to the disputed funds and disclaims any interest in doing so. (ECF No. 22 ¶ 33). As previously mentioned, default has been entered against Mr. Eastham and the Eastham Family Trust, the two other remaining parties. (ECF No. 31 ¶ 8). Wells Fargo never asserted an interest in the disputed funds. (ECF No. 1 ¶ 36). Throughout this litigation, no party other than Ms. Eastham has claimed any interest in the disputed funds. Accordingly, no pleading contests the fact that Ms. Eastham is entitled to the disputed funds, and she is entitled to judgment as a matter of law.
For the foregoing reasons, Plaintiff's motion for judgment on the pleadings will be granted. A separate order will follow.
