Indianapolis Colts v. Baltimore

741 F.2d 954 (7th Cir. 1984)



Interpleader is a suit in equity. Because the sole basis for equitable relief to the stakeholder is the danger of exposure to double liability or the vexation of conflicting claims, the stakeholder must have a real and reasonable fear of double liability or vexatious, conflicting claims to justify interpleader. 


State legislation was passed in which the city was given permission to acquire a football franchise by eminent domain. Immediately thereafter, plaintiff franchise signed a lease with defendant county management board in another state, which obligated the franchise to perform in that county's stadium. The franchise then moved the team during the night. The city filed a condemnation action in state court, which was removed to federal court. In this action for interpleader, the district court granted an injunction against the city, restraining it from pursuing its condemnation proceedings. The court vacated the injunction, holding that the city and the board did not have conflicting claims against the franchise. 


Did the district court have interpleader jurisdiction to hear this suit? 




An action in interpleader, which was designed to relieve a plaintiff from multiple claims on the same stake, did not lie. Because the plaintiff cannot assert a reasonable fear of multiple liability or vexatious, conflicting claims, interpleader jurisdiction was not proper. There is no other basis for federal jurisdiction in the federal district court in Indiana to hear the Colts' action and thus this suit must be dismissed.

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