Also known as: interplead · interpleads · interpleaded · interplea
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 action and require them to litigate entitlement among themselves. The device protects the stakeholder from the risk of double or multiple liability arising from inconsistent judgments in separate suits. Joinder remains available even when the claimants' titles lack a common origin or are adverse and independent and even when the stakeholder denies liability in whole or in part to any claimant.
Aurora Auctions holds the hammer price and buyer's premium from a sold painting. The consignor gallery, an heir of the original owner, and a cultural restitution foundation each demand the entire sum based on conflicting title documents. Aurora files an action naming all three as defendants and deposits the funds with the court so the claimants must litigate their rights to the proceeds in one proceeding.
State Farm issues a liability policy after a multi-vehicle accident. Multiple injured parties and estates file separate suits against the insured driver. State Farm brings an interpleader action and deposits the policy limits, allowing the claimants to litigate priority while preserving the right to a jury trial on disputed factual issues.
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An estate holds undivided interests in allotted Indian lands subject to federal restrictions. Several heirs assert competing claims to the same parcels after a statutory change in inheritance rules. The estate deposits the interests with the court and requires the heirs to resolve their entitlements in a single interpleader proceeding.
A stakeholder faces demands from claimants who have already filed suits in state court. The stakeholder commences a federal interpleader action, deposits the disputed fund, and obtains an order restraining the claimants from prosecuting the state proceedings until the federal court determines entitlement.
A corporation holds investment proceeds claimed by citizens of several states whose individual claims fall below the diversity threshold. The corporation files an interpleader action in federal court, joins all claimants, and deposits the fund so the court can adjudicate the competing rights under supplemental jurisdiction.
State Farm issues a single liability policy after a catastrophic bus accident. Numerous injured passengers and estates assert claims that together exceed the policy limits. State Farm deposits the full limits with the court and requires all claimants to litigate their shares in one interpleader action rather than facing repeated suits.
A stakeholder may invoke interpleader when facing claims that may expose it to double or multiple liability on the same fund or property. The rule expressly permits joinder even if the claims lack a common origin or are adverse and independent and even if the stakeholder denies liability in whole or in part.
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No. The rule permits interpleader when the titles on which the claims depend lack a common origin or are adverse and independent rather than identical. The key requirement is the risk of multiple liability to the stakeholder, not uniformity among the claimants' theories.
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Upon deposit the court may discharge the stakeholder from further liability and enjoin the claimants from pursuing separate actions against it. This eliminates the risk of inconsistent judgments and multiple payments on the same obligation.
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Yes. Rule 22(a)(2) authorizes a defendant facing comparable exposure to assert interpleader by crossclaim or counterclaim against the competing claimants.
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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…