Also known as:federal interpleaders · interpleader · statutory interpleader
Written by attorneys · grounded in primary & secondary sources — see below
A procedural device that permits a stakeholder holding money or property subject to competing claims to join all claimants as defendants in a single federal action and require them to litigate their respective rights among themselves. The device protects the stakeholder from the risk of double or multiple liability on the same obligation even when the claims lack a common origin or are adverse and independent. A defendant facing similar exposure may also invoke the device by crossclaim or counterclaim.
Sources & Authorities
How it applies
Common Examples
3
Insurer Joins Multiple Claimants
Prime Indemnity holds a $300,000 auto liability policy after a fatal multi-car collision. Roy, Bernard as personal representative of one estate, Wesley as personal representative of the second estate, and North Indemnity each demand payment from the policy limits. Prime files a federal interpleader action naming the four claimants as defendants and deposits the full limits with the court. The court requires the claimants to litigate priority among themselves and may enjoin separate suits.
Auction House Deposits Sale Proceeds
Red Museum holds $2.5 million in auction proceeds claimed in full by Ida under historical title documents, by Atlantic Gallery under international restitution conventions, and by Pinnacle Design under a consignment contract. Red Museum files a federal interpleader action naming the three claimants as defendants and deposits the funds with the court. The claimants must resolve their competing rights in one proceeding rather than exposing the museum to serial judgments.
Select any source to read its text and confirm it supports the definition.
Statutes
Federal Rules
Uniform Acts
Restatements
Hornbooks
Resort Deposits Wedding Deposits
Summit Stay holds $180,000 in prepaid wedding deposits demanded in conflicting amounts by Bryce under a venue agreement, by Sun Resorts under a separate planning contract, and by North Host under a travel reimbursement agreement. Summit Stay files a federal interpleader action naming the three claimants as defendants and deposits the money with the court. The court adjudicates the independent contractual claims in a single action and discharges the resort from further liability.
Common questions
Frequently Asked
4
When does Rule 22 permit a stakeholder to join adverse claimants even if their claims are independent?+
Rule 22(a)(1) expressly authorizes joinder when the claims lack a common origin or are adverse and independent rather than identical. The rule also permits interpleader even if the stakeholder denies liability in whole or in part to any claimant.
Supporting sources
May a defendant seek interpleader by crossclaim or counterclaim?+
Yes. Rule 22(a)(2) allows a defendant exposed to similar multiple-liability risk to seek interpleader through a crossclaim or counterclaim against the competing claimants.
Supporting sources
What relief may the court grant once the stakeholder deposits the disputed fund?+
The court may discharge the stakeholder from further liability, make any injunction permanent, and enter orders directing distribution of the fund among the claimants after determining their respective rights.
Supporting sources
Does interpleader require that the stakeholder already face pending lawsuits from multiple claimants?+
No. The rule requires only a realistic prospect that payment to one claimant will expose the stakeholder to later inconsistent judgments. Formal demands coupled with threats of suit suffice to establish the requisite risk of multiple liability.
Supporting sources
401 U.S. 37 (1971)Constitutional Law
…a subsequent statute' to the Act of 1793 . . . operates as an implied legislative amendment to it." We also added (3) the Interpleader Act of 1926 and (4) the Frazier-Lemke Act, 47 Stat. 1473. Toucey limited a line of cases dealing with nonstatutory exceptions to the "anti-injunction" Act. Shortly thereafter the current…