Also known as: interpleader · interpleaders · interplead · interpleaded · interpleading · interpleader suit · interpleader proceeding
Written by attorneys · grounded in primary & secondary sources — see below
A procedural mechanism by which a stakeholder holding money or property subject to conflicting claims joins all claimants as defendants in a single action. The court then determines the claimants' respective rights and may discharge the stakeholder from further liability upon deposit of the res. Joinder remains proper even when the claims lack a common origin or are adverse and independent.
Prime Indemnity faced demands from Roy, Bernard, Wesley, and North Indemnity that together exceeded its $300,000 policy limits after a multi-car collision. Prime deposited the full amount with the court and joined the four claimants as defendants. The court permitted the interpleader, allowing all parties to litigate their priority to the single fund in one proceeding.
A stakeholder facing adverse claims to insurance proceeds filed an interpleader action and sought a jury trial on factual issues of ownership. The court addressed whether the equitable origins of interpleader barred a jury on legal questions arising within the proceeding.
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State Farm held a modest liability policy after a bus accident produced multiple injury claims. The insurer filed an interpleader action to bring all claimants into federal court and obtain an injunction against separate state suits.
A stakeholder deposited disputed funds in one district while claimants resided elsewhere. The court considered whether the interpleader action should be transferred under forum non conveniens principles to a more convenient venue for the claimants.
A stakeholder commenced an interpleader action against out-of-state claimants. The court examined whether the claimants had contractually consented to service by a designated agent for purposes of the interpleader proceeding.
After an interpleader action resolved competing claims to a fund, one claimant attempted to relitigate the same ownership issue in a later suit. The court considered whether the prior interpleader judgment barred the second action.
A stakeholder may initiate interpleader when multiple claimants assert adverse claims that may expose the stakeholder to double or multiple liability. The rule expressly permits joinder even if the claims lack a common origin or are independent rather than identical.
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Yes. Rule 22(a)(2) authorizes a defendant exposed to comparable liability to seek interpleader by crossclaim or counterclaim against the competing claimants.
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The court may issue process restraining claimants from pursuing separate actions, determine the rights of the claimants to the res, discharge the stakeholder from further liability, and enter a permanent injunction protecting the stakeholder.
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No. The rule expressly states that interpleader is proper even when the claims lack a common origin or rest on adverse and independent titles.
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…of the Committee "strongly recommend[ed]" the elimination of diversity jurisdiction, save for "complex multi-state litigation, interpleader, and suits involving aliens." Id. , at 38-39; accord Subcommittee Report, at 454-458. "[N]o other step," the Committee's Report maintained, "will do anywhere nearly as much to reduce…