Summary
In this declaratory judgment action, Metropolitan Life Insurance Company sought summary judgment rescinding a disability insurance policy based on alleged fraudulent omissions and misrepresentations concerning Sheba S. Gopaul’s criminal history. The court denied Gopaul’s cross-motion, held that the omitted convictions were material as a matter of law, and found a genuine dispute regarding fraudulent intent. The court therefore granted MetLife’s motion in part and denied it in part.
Topics
Practice areas
Questions Presented
- Whether Gopaul was entitled to summary judgment on MetLife's declaratory judgment claim.
- Whether Gopaul's omission of several criminal convictions from her insurance application was a material misrepresentation as a matter of law.
- Whether the undisputed evidence established that Gopaul made the omissions with the purpose of defrauding MetLife, permitting summary judgment and rescission of the policy.
Holdings
- Gopaul was not entitled to summary judgment because her filing was properly construed primarily as an opposition to MetLife's motion and, in any event, the record did not establish that she was entitled to judgment as a matter of law.
- Gopaul's omission of several felony and misdemeanor convictions was material to MetLife's decision to issue the disability policy. The undisputed evidence established that MetLife would not have issued the policy had it known Gopaul's complete criminal history.
- Summary judgment was not warranted on whether Gopaul made the material omissions for the purpose of defrauding MetLife because a genuine dispute of material fact remained concerning her intent and alleged reliance on advice from her insurance broker.
Key quotations
“The undisputed material facts in this case show that Ms. Gopaul’s misrepresentations and/or omissions about her criminal history were material.” (Section IV.B)
“But there are material facts in dispute in this case about whether Ms. Gopaul’s misrepresentations and/or omissions about her criminal history were made for the purpose of defrauding MetLife.” (Section IV.C)
“While the evidence before the Court casts doubt on Ms. Gopaul’s version of these events, this is an issue to be resolved by the trier of fact at trial, after hearing the evidence and weighing the credibility of the witnesses.” (Section IV.C)
Factual background
Gopaul applied for a MetLife disability income insurance policy in June 2015 and answered yes to a question asking about felony or misdemeanor convictions, but disclosed only an unauthorized-use-of-vehicle offense. Criminal-history records later showed multiple additional felony and misdemeanor convictions in Maryland and Virginia. After Gopaul submitted a disability claim in 2020, MetLife rescinded the policy and tendered a refund of premiums, asserting that the omissions were material and fraudulent. MetLife's underwriting evidence showed that it would not have issued the policy had it known Gopaul's complete criminal history, but evidence concerning whether she intended to defraud MetLife, including her alleged reliance on an insurance broker, was disputed.
Procedural history
MetLife commenced the action on September 24, 2021. On March 19, 2025, MetLife moved for summary judgment under Federal Rule of Civil Procedure 56. Gopaul responded and filed a document styled as a cross-motion for summary judgment; the court construed it primarily as an opposition. The court denied Gopaul's cross-motion, granted MetLife's motion in part on materiality, and denied it in part because a genuine dispute remained concerning fraudulent intent.
Remand instructions
No remand was ordered. The case remains unresolved as to whether Gopaul's omissions were fraudulent and whether MetLife is entitled to rescind the policy.