Geler v. National Westminster Bank USA
United States District Court for the Southern District of New York
763 F. Supp. 722 (1991)
A $500,000 CD issued by National Westminster Bank (defendant) was payable on the depositor's death to the Gelers (plaintiffs), Israeli citizens, but the depositor's wife Susana, also an Israeli citizen, may have been a joint depositor; after both died, the Gelers sued the Bank in federal court for the funds, and Susana's estate administrator separately sued the Bank in New York state court once appointed. Because the Bank couldn't remove the state action (holding New York citizenship itself), it instead filed a Rule 22 interpleader action in federal court naming the Gelers and the administrator as competing claimants, and sought to enjoin the state court proceeding while the federal interpleader was pending.
Whether a federal court may enjoin state court proceedings involving disputed property being concurrently litigated in the federal court pursuant to a Federal Rule of Civil Procedure 22 interpleader action.