A few interesting notes from the Bressler team on federal court interpleader rulings in the first three months of 2026.
Two Cases Dismissing Counterclaims Against Stakeholder
Garretson Resol. Grp., Inc. v. Bolla, No. 25-cv-02836-AMO, 2026 U.S. Dist. LEXIS 14164 (N.D. Cal. Jan. 26, 2026)
Garretson Resol. relied on Hovis and the “well-settled principle of interpleader” that a stakeholder may not face liability for failing to resolve the controversy in one claimant’s favor to dismiss counterclaims for breach of contract and tortious interference with contractual relations. The “equivalency” between the claimant’s claim to the interpleader fund and against the stakeholder required dismissal of the counterclaim.
Am. Gen. Life Ins. Co. v. Lynch, No. 5:25-cv-00223-M-RN, Dkt. No. 28 (E.D.N.C. Mar. 18, 2026) (Bressler)
The Bressler team secured dismissal of a breach of contract counterclaim in Lynch. The Court relied on Hovis and other Fourth Circuit courts applying Hovis to dismiss the counterclaim that was “not independent of the interpleader controversy.” The Court rejected claimant’s contention that the counterclaim should survive because it was based on the stakeholder’s alleged failure to investigate the competing claims, determining this contention “finds no support in the law.”
Three Cases Denying Motions to Dismiss Claims for Interpleader Relief
Evanston Ins. Co. v. Affinitylifestyles.com, No. 2:25-cv-00670-CDS-EJY, 2026 U.S. Dist. LEXIS 56083 (D. Nev. Mar. 18, 2026)
Ohio Sec. Ins. Co. v. Affinitylifestyles.com, No. 2-25-cv-00399-CDS-EJY, 2026 U.S. Dist. LEXIS 60168 (D. Nev. Mar. 23, 2026)
Judge Cristina D. Silva denied motions to dismiss claims in two related interpleader cases arising out of competing claims to liability insurance policies by individuals who suffered bodily injuries after consuming Real Alkalized Water. Interestingly, the Court determined that the insurers’ years-long delays in initiating the interpleader actions were “unreasonable,” but nevertheless refused to apply the doctrine of laches to dismiss the claims since claimants had not shown they were prejudiced by the delay.
Dahleh v. Midland Nat’l Life Ins. Co., No. 24 C 11931, 2026 U.S. Dist. LEXIS 56715 (N.D. Ill. Mar. 18, 2026)
In Dahleh, the Court determined that the stakeholder’s declaratory judgment claim seeking to determine whether the policy remained in force did not negate its claim for interpleader relief since it could be pleaded in the alternative. The Court noted the interpleader rule itself notes it can invoked even where “plaintiff denies liability in whole or in part to any or all of the claimants.”
Four Cases Awarding Fees
Farmers New World Life Ins. Co. v. Advanced Surgical Care, LLC, No. 6:25-cv-00485-AA, 2026 U.S. Dist. LEXIS 12576 (D. Or. Jan. 23, 2026) (Bressler)
- Unopposed request for $7,315 from $1 million interpleader fund
Morgan v. Merrill, No. 4:24-cv-123-DJH-HBB, 2026 U.S. Dist. LEXIS 51143 (W.D. Ky. Mar. 12, 2026)
- Unopposed request for $5,000 from $220,000 interpleader fund
Argonaut Midwest Ins. Co. v. You Move We Move, Inc., No. 2:25-cv-00376-CDS-NJK, 2026 U.S. Dist. LEXIS 57545 (D. Nev. Mar. 19, 2026)
- Opposed request for $8,839.95 from $100,000 interpleader fund
- Court rejected claimants’ argument that stakeholder was depleting the fund since request satisfied the Lodestar requirements
Farmers New World Life Ins. Co. v. Pearce, No. 25-CV-1392 JLS (MSB), 2026 U.S. Dist. LEXIS 59424 (S.D. Cal. Mar. 20, 2026) (Bressler)
- Unopposed request for $7,500 from $1 million interpleader fund
Interpleader Statute Authorizes Nationwide Service of Process and Confers Nationwide Personal Jurisdiction
Morgan v. Merrill, No. 4:24-cv-123-DJH-HBB, 2026 U.S. Dist. LEXIS 51143 (W.D. Ky. Mar. 12, 2026)