Brief Fact Summary. Plaintiff, N.J. Sports Prods. et al., sought to place the disputed funds into an account and interplead all parties that assert a right to the funds.
Synopsis of Rule of Law. In order to plead an interpleader, there must be two or more claimants who are adverse, and there must be a limited fund or property that requires a resolution in one lawsuit.
If the stakeholder has a bona fide fear of adverse claims, interpleader relief is warranted.View Full Point of Law
Issue. The issue is whether Plaintiffs have asserted the correct venue in filing the interpleader in a New Jersey federal court.
Held. The court held that Plaintiff met the requirements for an interpleader against the possible claimants. There are two types of interpleader: rule interpleader which is governed by Fed. R. Civ. P. 22, and statutory interpleader which is governed by 28 U.S.C. Section:Section:1335, 1397 and 2361. Plaintiff satisfied rule interpleader since venue is proper in the district where the stakeholder (Plaintiff) resides. They also satisfy statutory interpleader because venue is where any claimant resides. Since stakeholder is a claimant, then venue is proper. Plaintiff also successfully established an adverse claim to the fund through the list of potential claimants.
Discussion. The court read 28 U.S.C. Section:1397 plainly to include a stakeholder as a claimant as well, since the statutory wording was “any claimant”.