In the case of New York Life Ins. Co. v. Dunlevy (241 U.S. 518 (1916)), NY Life had an insurance policy worth $2.5k. It was claimed by Gould (in Pennsylvania), his daughter Dunlevy (who lived in California), and a Department store in Pennsylvania. NY Life started an interpleader action in Pennsylvania State Court, who decided that Gould should get the money. Afterwards, Dunlevy sued in California Court saying that the Pennsylvania Court didnÕt bind her because they lacked in personam jurisdiction. The California Court agreed, awarding the money to Dunlevy. Therefore, NY Life had to pay twice on the same policy!
New York Life tried to bring Dunlevy into the case as an interpleader under Rule 22, but they were unable to get in personam jurisdiction on Dunlevy in the Pennsylvania Court. In response, Congress passed the Federal Interpleader Act (aka 28 U.S.C. § § 1335, 1397, 2361), which gives an express grant of Federal subject matter jurisdiction over interpleader claims (aka statutory interpleader). o This means that interpleader cases can be heard in Federal Court, which has jurisdiction over everybody, and this problem wonÕt happen again. In statutory interpleader you only need two adverse claimants with diversity. The claimants here are Gould and Dunlevy. Since it is a Federal law, venue exists wherever any claimant resides. Since it is a Federal law, there is nationwide service of process. o You can also sue under Rule 22, (aka rule interpleader), as an alternative basis, but there might be jurisdictional problems.
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