Also known as: Rule 22 interpleader · interpleader under Rule 22 · interpleader · FRCP 22 interpleader
Written by attorneys · grounded in primary & secondary sources — see below
A procedural device under the Federal Rules of Civil Procedure that permits a stakeholder facing multiple claims to the same fund or property to join the claimants as defendants and require them to litigate their rights in a single action. The device protects the stakeholder from the risk of double or multiple liability even when the claims lack a common origin or the stakeholder denies liability in whole or in part.
Rhea Reynolds holds a $900,000 insurance settlement as stakeholder after a disputed accident. Three separate parties each demand the entire sum under inconsistent beneficiary designations. Reynolds files a federal action naming the three as defendants and deposits the fund with the court. The court requires the claimants to litigate entitlement among themselves while shielding Reynolds from further exposure.
State Farm Fire and Casualty Co. faces claims from multiple injured passengers after a bus accident. The insurer deposits the policy limits and names all claimants as defendants in one federal proceeding. The court exercises nationwide service to bring distant claimants before it. All parties then resolve priority in the single action.
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Federated Dep’t Stores, Inc. faces two parallel suits seeking the same recovery. The company files an interpleader action joining both plaintiffs as defendants. The court consolidates the claims so the parties litigate their respective rights to the single fund. Federated is discharged once the court determines proper allocation.
Exxon Mobil Corp. holds proceeds claimed by numerous service-station operators. The company initiates interpleader and joins all adverse claimants as defendants. The court permits supplemental jurisdiction over the additional parties once one claim satisfies the amount requirement. The claimants then litigate their shares in one proceeding.
The Bremen faces competing demands for a single payment under a maritime contract. The company files an interpleader action in the agreed forum and joins both claimants. The court enforces the forum-selection clause while requiring the claimants to resolve their rights to the fund. The stakeholder obtains discharge after deposit.
Ross v. Bernhard involves a corporation holding disputed funds claimed by both the corporation and individual shareholders. The company files interpleader joining the adverse parties as defendants. The court treats the action as one in which the claimants must litigate entitlement. The stakeholder is released once the court adjudicates the claims.
Rule interpleader under Fed. R. Civ. P. 22 requires satisfaction of ordinary diversity or federal-question jurisdiction, complete diversity between the stakeholder and all claimants, and service under Rule 4. Statutory interpleader under 28 U.S.C. § 1335 requires only minimal diversity among claimants, a $500 amount in controversy, and nationwide service.
Supporting sources
Yes. Rule 22(a)(1)(B) expressly permits interpleader even though the plaintiff denies liability in whole or in part to any or all claimants. The stakeholder need only face a realistic prospect of multiple liability from the competing claims.
Supporting sources
No. Rule 22(a)(1)(A) authorizes interpleader even when the claims of the several claimants lack a common origin or are adverse and independent rather than identical. The only requirement is that the claims may expose the stakeholder to double or multiple liability.
Supporting sources
…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…