The Eleventh Circuit upheld a district court’s decision finding an underlying power of attorney valid, despite claims of mental incapacitation. Specifically, Jayson Tucker appealed the district court’s entry of judgment in favor of his brother, Shane Tucker, in an interpleader action filed by Metropolitan Life Insurance Company pursuant to 28 U.S.C. § 1335. The dispute between Jayson and Shayne concerned the proper beneficiary of the life insurance policy of their mother, Marjorie Tucker, a former General Electric employee.

Interpleaders may be statutory or rule-based – either utilized when the party in control of a particular fund seeks the court’s control thereof while the court determines which of multiple parties claiming stake therein is entitled to the fund. Statutory interpleader is pursuant to 28 U.S.C § 1335, which provides, in part, that district courts have original jurisdiction of an interpleader filed by an individual or entity having in his or its custody money or property valued at $500 or more, if 1) two or more adverse claimants of diverse citizenship are claiming or may claim to be entitled to the money or property and 2) plaintiff has deposited the money or property into the court, with plaintiff to comply with the court’s order with respect to the money or property at issue. Rule-based interpleader is based upon Rule 22 of the Federal Rules of Civil Procedure, which allows a plaintiff to join as defendants persons with claims that may expose a plaintiff to double or multiple liability.

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.

This was the holding of the Seventh Circuit’s recent decision in State Farm Life Ins. Co. v. Jonas, No. 14-1464 (7th Cir. Dec. 31, 2014), an opinion authored by Judge Easterbrook, in which Judges Flaum and Kanne joined. Specifically, 28 U.S.C. § 1335 provides federal courts with jurisdiction over certain interpleader actions, but it requires (1) minimal diversity and (2) that “the plaintiff has deposited such money or property... into the registry of the court.” Without that “cash on the barrelhead,” the Seventh Circuit held that it lacked jurisdiction.Jonas began with a dispute over reciprocal policies of life insurance.