Also known as: trial of the right of property · interpleader · trial of title
Written by attorneys · grounded in primary & secondary sources — see below
A procedural device by which a stakeholder holding property subject to competing claims may join the claimants as defendants and require them to litigate their respective rights to the property in a single proceeding.
Pioneer Motors holds repossessed vehicle sale proceeds while Urban Drive, Jared, and Jack each demand the full amount under separate security interests, guaranties, and purchase documents. Pioneer deposits the funds with the court and joins the three claimants so they may litigate their ownership rights among themselves. The court permits the intervention and resolves the competing claims in one proceeding.
Frontier Rural holds warehouse receipts for soybeans demanded by Sigma Livestock under a security interest, Lake Greenhouse under a sales contract, and Selena under agricultural liens. Frontier deposits the soybeans with the court and requires the claimants to establish their respective ownership rights in a single action. The intervention consolidates the title disputes and shields Frontier from inconsistent obligations.
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Red Museum holds auction proceeds claimed by Ida under historical title documents, Atlantic Gallery under restitution conventions, and Pinnacle Design under a consignment contract. Red Museum deposits the funds and brings the claimants into court to litigate their ownership interests. The intervention allows the court to rank the competing property claims without exposing the museum to multiple liability.
Summit Stay holds prepaid wedding deposits claimed by Bryce under a venue agreement, Sun Resorts under a planning contract, and North Host under a travel contract. Summit deposits the money and joins the claimants so each may prove its right to the fund. The intervention resolves the ownership dispute in one proceeding.
Prime Indemnity holds policy limits claimed by Roy for bodily injury, Bernard and Wesley for wrongful death, and North Indemnity for reimbursement. Prime deposits the limits and requires the claimants to litigate their respective rights to the fund. The intervention prevents the insurer from facing inconsistent judgments on the same proceeds.
Webb’s Fabulous Pharmacies holds escrowed funds claimed by multiple creditors after a business sale. The stakeholder deposits the money and joins the claimants to determine which party holds superior title. The intervention resolves the ownership contest in a single action.
A stakeholder facing claims that may expose it to double or multiple liability may join the claimants as defendants and require them to litigate their rights to the property. Joinder remains proper even when the claims lack a common origin or are adverse and independent. The stakeholder may also deny liability in whole or in part to any claimant.
No. The rule expressly permits interpleader when claims lack a common origin or rest on independent legal theories. The key inquiry is whether the stakeholder faces a realistic risk of multiple liability from the competing demands.
No. The risk of multiple liability arises from the existence of conflicting demands and threats of suit, not from prior payment. Depositing the property with the court protects the stakeholder from inconsistent obligations.
Yes. A defendant facing comparable exposure may assert interpleader through a crossclaim or counterclaim against the other claimants.
The court may restrain other proceedings, hear and determine the claims, discharge the stakeholder from further liability, and enter orders enforcing its judgment regarding the property.
…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…