Rule 22.Interpleader
Last verified July 2, 2026
Full Text of Rule 22
Advisory Commission Comments
Plain-English Summary
Rule 22.01 lets a party holding property or facing a potential debt — typically an insurer or a stakeholder caught between rival claimants — join those claimants as defendants and require them to interplead when their claims expose the party to double or multiple liability. The claims do not need to be identical or share a common origin, and it is not a valid objection that they are adverse to and independent of one another. The party seeking interpleader can even deny liability, in whole or in part, to any or all of the claimants and still use the rule. A defendant facing the same kind of exposure can seek interpleader through a cross-claim or counterclaim, and the rule supplements, rather than limits, the ordinary joinder of parties allowed under Rule 20.
Rule 22.02 covers the mechanics once interpleader is sought. A party who admits liability for the property or amount in dispute may, on court order, deposit it with the court, otherwise preserve it, or secure it with a bond sufficient to cover the admitted liability. Once that happens, the court can enjoin every party before it from starting or pursuing any other action over the same subject matter, and after a hearing, it can discharge the party who sought interpleader from further liability regarding the deposited or secured property, before it ever resolves which claimant is entitled to it.
Interpleader traces back to equity practice and exists to protect a stakeholder from having to guess which of several rival claimants will ultimately prevail, and from risking inconsistent judgments in separate lawsuits over the same fund. Because Tennessee has no equivalent to the federal statute that lets a stakeholder reach out-of-state claimants through nationwide service, getting personal jurisdiction over every claimant can be a real practical obstacle to using the rule.
Frequently Asked Questions
Do the claims against a stakeholder need to be identical to use interpleader?
No. Rule 22.01 allows interpleader even when the claimants' claims differ, do not share a common origin, or are adverse to and independent of one another.
Can a party use interpleader while denying it owes anything?
Yes. Rule 22.01 lets a party seeking interpleader deny liability, in whole or in part, to any or all of the claimants while still forcing them into a single action.
What happens to the disputed property once interpleader is granted?
Under Rule 22.02, a party who admits liability may deposit the property or amount with the court, preserve it, or secure it with a bond. The court can then enjoin other lawsuits over the same subject matter and, after a hearing, discharge the depositing party from further liability regarding it.
Advisory Commission Comments.
Rule 22.01 provides for interpleader of persons having claims against the plaintiff and specifies that it also is available to a defendant by way of cross claim or counterclaim. Rule 22.02 provides for deposit with the court of any property or amount involved as to which the party seeking interpleader admits liability. By depositing the property or amount claimed with the court, or making bond to secure payment of an admitted liability, a party may be protected against suit by any of the claimants, and may upon the hearing, be discharged from liability before the rights of the interpleaded parties have been determined.