Farmers Irrigating Ditch & Reservoir Co. v. Kane

Summary

The Tenth Circuit held that Farmers Irrigating Ditch & Reservoir Company, an admitted tortfeasor responsible for a reservoir flood, could not use interpleader to tender its purportedly limited assets and obtain discharge from further liability. Relying on the rule that a tortfeasor cannot obtain interpleader protection against the consequences of its own wrong, the court reversed and remanded with directions to dismiss Farmers from the proceeding.

Holdings

1. An admitted tortfeasor is not a proper party to interpleader and cannot use interpleader to obtain protection against the consequences of its own wrongdoing.
2. The insurers' interpleader action did not make Farmers a proper interpleader plaintiff; Farmers had to independently satisfy the requirements for interpleader.

Questions Presented

1. Whether an admitted tortfeasor may invoke interpleader by tendering a minimal amount purportedly representing all of its assets and obtain discharge from further liability for the tort.
2. Whether Farmers was a proper party to the interpleader proceeding and could receive injunctive protection against claims arising from the flood.

Disposition

reversed_and_remanded