Sunday, November 24, 2013

State Farm Fire & Casualty Co. v. Tashire case brief

State Farm Fire & Casualty Co. v. Tashire case brief summary
386 U.S. 523 (1967)

Petitioners, defendants in a mass tort accident, sought review of a judgment from the United States Court of Appeals for the Ninth Circuit, which dissolved an injunction that prohibited the prosecution of any claims against them outside of their interpleader action. Respondents were some of the other defendants and injured passengers.

The court reversed a judgment that dissolved an injunction in an interpleader action pursuant to 28 U.S.C.S. § 1335. Following an accident between a bus and an automobile, multiple injured passengers brought suits against multiple defendants. Petitioner, the insurance company of one of the defendants, the driver of the automobile, brought the interpleader action to consolidate all claims against the available proceeds of the policy. The lower court granted an injunction prohibiting the prosecution of any claims against petitioner outside of the interpleader action and extended that injunction to include several other defendants in the underlying action.


  • The court held that the interpleader statute did permit an injunction to consolidate the claims against petitioner, and rejected the argument that petitioner had to wait for those claims to be reduced to a judgment. 
  • The court held, however, that the lower court exceeded its authority in extending the injunctive protection to the other defendants in the underlying action, who were not related to the fund of insurance proceeds.
The court reversed the judgment and held that the interpleader statute did authorize an injunction against claims outside the interpleader action, but only against the insurance company defendant in control of the fund of proceeds from the insurance policy. The court affirmed the injunction as modified.

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