## Facts

- A bank issued a 90-day renewable certificate of deposit (about $500,000) titled as a Totten trust payable at the death of the depositor(s) to three named beneficiaries.
- A core factual dispute was whether the CD was owned solely by the decedent husband or jointly with his wife.
- After the husband died, the wife withdrew the CD proceeds; after beneficiaries complained, she returned the funds to the bank upon demand.
- After the wife later died, the beneficiaries sued the bank in federal court for payment as Totten trust beneficiaries.
- The wife’s estate administrator indicated he would intervene in the federal case after receiving letters of administration, which contributed to delay.
- After receiving letters, the administrator sued the bank in New York state court over the same funds instead of intervening.
- The bank filed a federal interpleader action naming the beneficiaries and the administrator as competing claimants and sought to stay the state action; the federal cases were consolidated.

## Issues

1. Whether the beneficiaries were entitled to partial summary judgment on their claim to the CD proceeds, or whether disputed facts about ownership and intent precluded judgment as a matter of law.
2. Whether the federal court could enjoin the administrator’s pending state-court action under the Anti-Injunction Act in connection with the bank’s interpleader.

## Decision

- The court denied the beneficiaries’ motion for partial summary judgment because genuine disputes of material fact existed regarding ownership of the CD and the intent governing the account arrangement.
- The court treated the bank’s interpleader as Rule 22 interpleader, not statutory interpleader, because minimal diversity among adverse claimants was not established for 28 U.S.C. § 1335.
- The court denied the bank’s motion to enjoin the state-court action because the Anti-Injunction Act’s exceptions were not satisfied and the bank had not shown grounds for federal interference with the state proceeding at that stage.

## Legal Principles

- Summary judgment is improper when material facts—such as ownership and intent in a deposit arrangement—are genuinely disputed and require factfinding.
- Statutory interpleader under 28 U.S.C. § 1335 requires at least minimal diversity among adverse claimants; absent that, interpleader may proceed, if at all, under Federal Rule of Civil Procedure 22 with an independent jurisdictional basis.
- The Anti-Injunction Act, 28 U.S.C. § 2283, bars federal injunctions against state proceedings unless an exception applies: express congressional authorization, necessity in aid of federal jurisdiction, or protection/effectuation of a federal judgment.
- When no federal judgment exists and the interpleader is not statutory, a federal court generally will not halt parallel state litigation based on a stakeholder’s risk of multiple suits, particularly where state-court remedies are available.

## Conclusion

The court left the competing claims to the CD unresolved on the merits by denying summary judgment due to disputed facts about ownership and intent, and it refused to stop the parallel state action because the Anti-Injunction Act barred an injunction on the record presented and comity favored allowing the state case to proceed.


Geler v. Nat'l Westminster Bank USA, 763 F. Supp. 722 (S.D.N.Y. 1991)