In determining whether interpleader is appropriate, the primary consideration is whether the stakeholder legitimately fears multiple liability. Michigan Teamsters Joint Council No. 43 v. Bufalino, 626 F. Supp. 51, 53 (E.D. Mich. 1985); Wright Miller at § 1704. If interpleader is appropriate and the stakeholder is disinterested, the Court may discharge the stakeholder. See e.g., Aon Corp. v. Hohlweck, 223 F. Supp. 2d 510, 514 (S.D.N.Y. 2002).
Claimants' action for interpleader cannot lie for they do not face multiple liability and have an interest in the alleged stake — the property. See Michigan Teamsters Joint Council No. 43 v. Bufalino, 626 F. Supp. 51 (E.D.Mich. 1985) (requiring a legitimate threat of multiple loss); Purdes v. Carvel Hall, Inc., 301 F. Supp. 1256 (S.D. Iowa 1969) (requiring a stakeholder to acknowledge his own lack of entitlement to the stake). Because the claimants do not meet these requirements, their counterclaim for an interpleader action must be dismissed.
In Local No. 1 (ACA) v. International Brotherhood of Teamsters, 461 F. Supp. 961 (E.D.Pa. 1978), affirmed in part and reversed in part, 614 F.2d 846 (3rd Cir. 1980), the district court, without discussing the validity of a similar forfeiture provision, forfeited the local's assets to the union upon revocation of the local's charter. See, Michigan Teamsters Joint Council v. Bufalino, 626 F. Supp. 51 (E.D. Mich. 1985). In International Brotherhood of Teamsters v. United States, 275 F.2d 610 (4th Cir. 1960), the court, again without discussing the validity of forfeiture, discussed the constitution provisions for forfeiture of funds and property in holding that the local was not an autonomous body, but was a subdivision of the union, subject to the union's control.