Republic of Philippines v. Pimentel

Human rights victims of Philippine President Ferdinand Marcos (Pimentel) obtained a nearly $2 billion judgment and sought to attach a Merrill Lynch (plaintiff) brokerage account owned by Arelma, S.A., a Marcos-formed company. The Republic of the Philippines and its Presidential Commission on Good Governance (the Republic) claimed the account belonged to the Republic under Philippine law and asked Merrill Lynch to transfer the funds pending a ruling by a Philippine court, but Merrill Lynch instead filed an interpleader action naming the Republic, Arelma, a Philippine bank, Pimentel, and others as defendants. The Republic was dismissed on sovereign immunity grounds but then moved to dismiss the entire action as an indispensable party under Federal Rule of Civil Procedure (FRCP) 19; the district court denied the motion, and after appellate proceedings the case eventually reached the Supreme Court.