Indianapolis Colts v. Mayor and City Council of Baltimore
United States Court of Appeals for the Seventh Circuit
741 F.2d 954 (1984)
After Maryland authorized Baltimore (defendant) to acquire the Colts by eminent domain and Baltimore filed a condemnation suit, owner Robert Irsay moved the team overnight to Indianapolis and signed a lease with the Capital Improvement Board (CIB) that would automatically terminate if eminent domain succeeded, and separately gave CIB a right to find a buyer if Irsay chose to sell. The Colts (plaintiff) then filed an interpleader action in Indiana federal court claiming conflicting claims between CIB and Baltimore, and the district court enjoined Baltimore from pursuing its condemnation suit and a related action against the NFL; Baltimore appealed.
Whether a plaintiff may maintain an interpleader action in the absence of conflicting claims to a single stake, where the plaintiff faces no risk of multiple liabilities.