Judge: Yolanda Orozco, Case: 22STCP02379, Date: 2022-08-18 Tentative Ruling

Case Number: 22STCP02379    Hearing Date: August 18, 2022    Dept: 31

PETITION FOR APPROVAL OF TRANSFER OF
STRUCTURED SETTLEMENT PAYMENT RIGHTS IS GRANTED
 

Background 

Petitioner Stone Street Obligations, LLC moves the Court for approval of a transfer of structured settlement payment rights from named payee Joshua McIntyre (“McIntyre” or “payee”). 

On August 04, 2022, the hearing was continued so that the petitioner could provide Payee’s address pursuant to Insurance Code Section 10139.5(c) and so that Payee could provide a summary outlining the payee’s reasons for completing prior transfers of structured settlement payments. (Min. Or. 08/09/22.) 

Legal Standard 

This Petition is governed by Insurance Code sections 10134–10139.5. (See 321 Henderson Receivables Origination LLC v. Sioteco (2009) 173 Cal.App.4th 1059, 1066.)  Under Insurance Code section 10137, a transfer of structured settlement payment rights is void unless a court reviews and approves the transfer and finds the following conditions are met: 

a)     The transfer of the structured settlement payment rights is fair and reasonable and in the best interest of the payee, taking into account the welfare and support of his or her dependents.

b)     The transfer complies with the requirements of this article and will not contravene other applicable law, and the court has reviewed and approved the transfer as provided in Section 10139.5. 

Pursuant to Insurance Code section 10139.5(a), the Court must make the following express findings as to a transfer of structured settlement payment rights: 

(1)   The transfer is in the best interest of the payee, taking into account the welfare and support of the payee's dependents.

(2)   The payee has been advised in writing by the transferee to seek independent professional advice regarding the transfer and has either received that advice or knowingly waived receipt of that advice in writing.

(3)   The transferee has provided the payee with a disclosure form that complies with Section 10136 and the transfer agreement complies with Sections 10136 and 10138.

(4)   The transfer does not contravene any applicable statute or the order of any court or other government authority.

(5)   The payee reasonably understands the terms of the transfer agreement, including the terms set forth in the disclosure statement required by Section 10136.

(6)   The payee understands and does not wish to exercise the payee's right to cancel the transfer agreement. 

The transfer agreement is effective only upon approval in a final court order. (Ins. Code, § 10139.5(a).) 

When determining whether the proposed transfer should be approved, including whether the transfer is fair, reasonable, and in the payee’s best interest, the Court shall consider the totality of the circumstances, including, but not limited to:

(1)   the reasonable preference and desire of the payee to complete the proposed transaction, taking into account the payee’s age, mental capacity, legal knowledge, and apparent maturity level;

(2)   the stated purpose of the transfer;

(3)   the payee’s financial and economic situation;

(4)   the terms of the transaction, including whether the payee is transferring monthly or lump sum payments or all or a portion of his or her future payments;

(5)    whether the future periodic payments were intended to pay for future medical care of the payee related to the incident that was the subject of the settlement;

(6)   whether the payee has other means of income or support sufficient to meet the payee’s future financial obligations for support of payee’s dependents, such as child support;

(7)   whether there were previous transactions involving payee’s structured settlement payments; and

(8)   whether the payee and his or her dependents are facing a hardship situation. (Ins. Code, § 10139.5, subd. (b).

Procedurally, Insurance Code section 10136, subdivision (b) provides that ten or more days before the payee executes a transfer agreement, the transferee shall provide the payee with a separate written disclosure statement, accurately completed with the information that applies to the transfer agreement in at least 12-point type. The Court-approval process requires the transferee to file a petition in the county in which the transferor resides for approval of the transfer. (Ins. Code, § 10139.5, subd. (f)(1).) Further, at the time of filing such a petition, the transferee shall file a copy of the petition with the California Attorney General. (Ins. Code, § 10139.) Lastly, the Court shall retain continuing jurisdiction to interpret and monitor the implementation of the transfer agreement as justice requires. (Id. § 10139.5, subd. (i).) 

Discussion 

Payee submitted a supplemental declaration outlining the reasons why he pursued a transfer of structured settlement payment rights on 12/06/2007, 10/20/2010, 8/10/2011, 9/22/2014, 8/31/2015, and 10/04/2019. (McIntrye Supp. Decl. ¶ 4.) The Court is satisfied with the response. 

Although Petitioner did not provide Payee’s address, it can be found in the Service List attached to Payee’s Supplemental Declaration. 

Therefore, the Court is satisfied with Petitioner's compliance with the requirements of Insurance Code sections 10134–10139.5. 

The Petition is GRANTED. 

Petitioner to give notice. 

The parties are strongly encouraged to attend all scheduled hearings virtually or by audio. Effective July 20, 2020, all matters will be scheduled virtually and/or with audio through the Court’s LACourtConnect technology. The parties are strongly encouraged to use LACourtConnect for all their matters. All masking protocols will be observed at the Courthouse and in the courtrooms.