New York Life Ins. Co. v. Dunlevy 241 U.S. 518 (1916) NY Life issued an insurance policy worth $2.5k. Three people filed claims with NY Life for the money: A guy named Gould (in Pennsylvania), Gould's daughter Dunlevy (who lived in California), A department store in Pennsylvania. NY Life started an interpleader action in Pennsylvania State Court, who decided that Gould should get the money. NY 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. Afterwards, Dunlevy sued in California Court saying that the Pennsylvania Court didn't bind her because they lacked in personam jurisdiction. The California Court found that the Pennsylvania decision was not binding, and awarded the money to Dunlevy. Therefore, NY Life had to pay twice on the same policy! The whole point of an interpleader action is to not have to pay multiple claims on the same policy. This case illustrated that the system was broken. 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). This means that interpleader cases can be heard in Federal Court, which has jurisdiction over everybody, and this problem won't happen again. In statutory interpleader you only need two adverse claimants with diversity. The claimants here were Gould and Dunlevy. Remember, since it is a Federal law, venue exists wherever any claimant resides. Also remember that since it is a Federal law, there is nationwide service of process. Btw, you can also sue under Rule 22, (aka rule interpleader), as an alternative basis, but there might be jurisdictional problems (as seen in this case).