licts frequently emerge when a policyholder makes alterations to her beneficiary designations shortly before passing away. Last-minute changes can prompt inquiries into the policyholder’s mental capacity when the change was made and whether the new beneficiary exerted any undue influence.Types of InterpleadersThere are two types of interpleader actions available in federal court:Rule Interpleader (Federal Rule of Civil Procedure 22): This type of interpleader requires the stakeholder to establish independent grounds for federal jurisdiction, such as diversity of citizenship or a federal question.Statutory Interpleader (28 U.S.C. § 1335): Statutory interpleader has less stringent jurisdictional requirements, requiring only minimal diversity among the claimants and a stake valued at $500 or more. It also requires the stakeholder to deposit the funds or property with the court or post a bond.There are two advantages to proceeding with a statutory interpleader where possible. First, under 28 U.S.C. § 2361, Congress granted the district courts authority to issue nationwide service of process in statutory interpleader actions, which establishes personal jurisdiction over the interpleader defendants. Second, 28 U.S.C. § 2361 allows the district courts to issue a permanent injunction against all claimants to the funds, providing the insurer with an additional layer of protection.Best Practices in Interpleader ActionsNavigating the interpleader process effectively requires careful planning and execution. Here are some best practices for stakeholders:Take Action Early: Insurers should be proactive about competing claims as soon as they are received. In many instances, competing claims can be resolved without proceeding to litigation. It is advisable to notify the claimants of the details of the competing claims and allow a period in which the claimants may resolve their dispute. It can often be helpful to have outside counsel serve as an intermediary to answer questions about settlement and/

The Federal Interpleader Act, however, allows for nationwide service of process by stakeholders on claimants. 28 U.S.C. § 2361. If the definition of “residence” in the General Venue Statute applies to the Federal Interpleader Act, then venue would at least arguably be proper in an interpleader action in any district court in the country, so long as one of the claimants had sufficient ties to the state in question to allow lawful service of process.

Under the Interpleader Statute, generally, a plaintiff may deposit money or property to the court's registry and defendants then make competing claims against that deposited money or property. Pursuant to a corresponding statute, 28 U.S.C. § 2361, the court may issue an order restraining the competing claimants from commencing or prosecuting claims related to the subject matter of the interpleader case in other forums. Yet, the underlying circumstances of the O.W. Bunker-related interpleader cases raised unprecedented issues concerning United States bankruptcy law, maritime law, and interpleader law.

Under 28 U.S.C. §1397, the venue for a statutory interpleader action is proper in any district where a claimant resides. 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.