Seventh Circuit Requires "Cash On The Barrelhead" From Interpleaders

Judge Easterbrook and his colleagues on the U.S. Court of Appeals for the Seventh Circuit aren't about to exercise jurisdiction over a civil action of interpleader merely on credit or promises to pay. The plaintiff has to pony up the goods.

This was the holding of the Seventh Circuit's recent decision in State Farm Life Ins. Co. v. Jonas, No. 14-1464 (7th Cir. Dec. 31, 2014), an opinion authored by Judge Easterbrook, in which Judges Flaum and Kanne joined. Specifically, 28 U.S.C. § 1335 provides federal courts with jurisdiction over certain interpleader actions, but it requires (1) minimal diversity and (2) that "the plaintiff has deposited such money or property . . . into the registry of the court." Without that "cash on the barrelhead," the Seventh Circuit held that it lacked jurisdiction.