Brief Fact Summary. Plaintiffs, lessees, brought an interpleader action against Defendants, landowners, and against Defendant Independent Distributing Company to have the Defendants determine to whom Plaintiffs owed royalties under the lease. Defendants, landowners, demurred, which the trial court sustained, on the grounds that a tenant cannot question the landlord’s title to the property on the date of the lease. Plaintiffs appealed.
Synopsis of Rule of Law. The common law elements of interpleader are: (1) That the debt, duty is claimed by all parties against whom relief is demanded; (2) The claims must be dependent or come from a common source; (3) The plaintiff cannot have an interest in the subject matter and (4) The plaintiff cannot have an independent liability to any of the claimants. The purpose of interpleader is to prevent “double vexation” of liability and allow the plaintiff to have claimants resolve disputes in property amongst themselves.
Facts. Plaintiffs Hancock Oil Co. and R.R. Bush Oil Co. leased land from the Defendants Hopkins. Royalties on the land accrued. Defendant Independent Distributing Co., (”Independent”), a co-partnership, claimed that the Hopkins held the land in trust for it and that royalties should be paid to Independent. The Hopkins claimed the royalties should be paid to them, as landowners. Plaintiffs brought an interpleader action against both Defendants in order to have Defendants determine to whom Plaintiffs owed the royalties. Defendants Hopkins demurred, which the court sustained, on the ground that a tenant may not question the landlord’s title to the land on the date of the lease. Plaintiffs appealed.
Issue. Is the obligation to pay rent an independent liability to the claimants in the action such that Plaintiffs may not bring an action for interpleader? May a tenant bring an interpleader action against its landlord notwithstanding the rule that a tenant cannot question the landlord’s title on the date of the lease?