Had Moore’s brother sought distributions from the retirement plans, the plans would have been faced with a competing claim from the widow. In that event, the plans would have had indifferent stakeholders and their recourse would have been to file an interpleader action under Fed. R. Civ. P. 22, which provides: “Persons with claims that may expose a plaintiff to double or multiple liability may be joined as defendants and required to interplead.”InMoore, the resolution of who was entitled to the retirement benefits was resolved by a breach of contract lawsuit, which was successful.

Although vessels were "happy" to pay for the bunkers, they did not want to pay more than once. Therefore, many vessels invoked United States federal court jurisdiction based on 28 U.S.C. § 1335 (the "Interpleader Statute") or Federal Rule of Civil Procedure 22 (the "Interpleader Rule"), both of which are designed to protect stakeholders facing multiple claims for a single obligation. More than thirty related interpleader cases are now pending before United States District Judge Valerie E. Caproni in the United States District Court for the Southern District of New York.

Furthermore, 28 U.S.C. §2361 provides for nationwide service of process and bestows direct authority for federal courts to discharge the stakeholder from liability and to enjoin the claimants from further litigation over the res. Federal Rule of Civil Procedure 22 governs a rule interpleader. (Alabama Rule of Civil Procedure 22 is similar for state court actions.)