musicfor18 wrote:The confusing thing is what does "complete diversity" mean for rule interpleader? Who exactly has to be diverse from whom? Shonholtz said you need complete diversity between the stakeholder and the claimants, but I'm not entirely sure what that means.
For a statutory interpleader, the diversity requirement is satisfied so long as two or more claimants are from a different state, it is irrelevant where the stakeholder is from. I.e. P (from A) v. D1 (from A) + D2 (from B) is OK for minimum diversity. Whereas obviously this would not be ok under the regular diversity rule.
So three situation:
P (from A) v. D1 (from B) + D2 (from C) = OK for Rule, OK for Statute
P (from A) v. D1 (from A) + D2 (from B) = NOT OK for Rule, OK for Statute
P (from A) v. D1 (from B) + D2 (from B) = OK for Rule, NOT OK for Statute
Remember, amount of controversy must still be satisfied. i.e. $500 for statute and $75,000 for rule. Furthermore, a rule interpleader can arise under federal question jurisdiction, whereas statutory interpleader is a modified diversity jurisdiction.