Bankers Life and Casualty Company v. Mallin

Background

Bankers Life and Casualty Company moved under Federal Rules of Civil Procedure 22 and 67 to deposit disputed proceeds with the court. Maria V. Pucciarelli filed a statement of non-opposition. Nicole M. Mallin was in default, and a motion for default judgment against Mallin was pending.

Court’s Analysis

Interpleader is a procedure intended to protect a stakeholder from multiple liability and the expense of multiple lawsuits. The court described two stages: first, determining whether there is one fund and adverse claimants; and second, determining the claimants’ respective rights.

Rule 67 allows a party, with notice to the other parties and the court’s permission, to deposit money or another deliverable item with the court. The court also explained that the party seeking interpleader must have a good-faith belief that there are, or may be, colorable competing claims. That requirement is not demanding.

The court found that Bankers Life satisfied the requirements for bringing an interpleader action, including showing a good-faith belief that Pucciarelli and Mallin might have competing claims to the disputed proceeds.

Ruling

Judge Rita F. Lin granted Bankers Life’s motion for an interpleader deposit. The disputed proceeds—$511,337.39—must be deposited in the Court Registry Investment System Disputed Ownership Fund until the proper beneficiary is determined. The order resolved whether the money could be deposited; it did not determine which claimant is the proper beneficiary.