Also known as: enterpleader · interpleader
Written by attorneys · grounded in primary & secondary sources — see below
A procedural mechanism by which a stakeholder holding property or funds subject to conflicting claims may join all claimants as defendants in a single action and require them to litigate their respective rights among themselves. 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.
Keller & Ross holds $600,000 in trust from a settled business dispute. Former partners Diaz and Monroe, the client's bankruptcy trustee, and Apex Capital each assert conflicting liens and assignments against the identical proceeds. The firm joins all four claimants as defendants, deposits the money with the court, and requires them to establish priority among themselves.
State Farm issues a liability policy after a bus collision injuring passengers from several states. Four injured passengers sue separately in state court seeking damages exceeding policy limits. The insurer files an interpleader action joining all claimants and deposits the policy proceeds so the court can allocate the limited fund.
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Federated Department Stores faces two separate federal actions brought by the same plaintiff asserting identical claims. The store deposits the disputed amount into court and joins the plaintiff in an interpleader proceeding that consolidates the overlapping demands into one adjudication.
An estate holds undivided interests in allotted lands claimed by multiple heirs under conflicting descent rules. The administrator joins all heirs as defendants, deposits the property interests with the court, and requires them to litigate ownership percentages in a single interpleader action.
Webb's Fabulous Pharmacies receives client funds placed in an interest-bearing account later claimed by both the clients and a county clerk asserting statutory fees. The pharmacy joins both groups as defendants and deposits the principal so the court can determine entitlement without exposing the firm to duplicate liability.
Exxon Mobil holds settlement proceeds demanded by thousands of dealers asserting separate breach claims. The company files an interpleader action joining representative claimants, deposits the fund, and obtains a single determination of allocation that binds the entire class.
A stakeholder may invoke interpleader when multiple claimants assert rights that could expose it to double or multiple liability, even while denying any obligation to some or all of them. The rule expressly permits this approach so long as the competing demands create a realistic risk of inconsistent judgments.
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No. Interpleader is available even when the claimants' titles or claims lack a common origin or are adverse and independent rather than identical. The controlling requirement is exposure to multiple liability on the same property or fund.
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The court may restrain claimants from pursuing separate actions, order the stakeholder to deposit the disputed property, adjudicate the competing claims, and discharge the stakeholder from further liability once the fund is distributed according to the judgment.
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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…