## Facts

- A vessel operator ordered fuel bunkers for three vessels through an intermediary bunker trader, which subcontracted a physical supplier to deliver the bunkers in Tacoma, Washington.
- The physical supplier delivered the bunkers and invoiced the intermediary, expecting payment from the intermediary rather than from the vessel operator.
- After delivery, the intermediary’s corporate group entered insolvency proceedings, and multiple parties asserted entitlement to the same bunker-payment obligation, including an assignee bank claiming rights to receivables.
- The physical supplier filed separate federal **in rem** actions against the vessels in Washington and California, obtained arrest warrants, and asserted maritime liens for providing “necessaries” under the Commercial Instruments and Maritime Liens Act (CIMLA).
- The vessel operator filed a statutory interpleader action in the Southern District of New York, sought to deposit/post security for the bunker-payment obligation, and requested an injunction barring related proceedings “in any jurisdiction.”
- The district court entered an injunction under 28 U.S.C. § 2361 restraining defendants from commencing or prosecuting any related actions and required the vessel operator to post a bond for the amount owed plus interest and costs.
- The physical supplier moved to vacate or modify the injunction, arguing lack of interpleader jurisdiction, improper restraint of **in rem** lien enforcement and foreign proceedings, and inadequate jurisdictional basis to bind maritime arrest actions. The district court denied the motion.

## Issues

1. Whether statutory interpleader jurisdiction existed under 28 U.S.C. § 1335 where competing claimants asserted different legal theories (**in rem** maritime liens versus **in personam** contract/assignment claims) arising from the same bunker-payment obligation.
2. Whether the vessel operator’s filing of interpleader and posting of adequate security constituted consent sufficient for the court to exercise jurisdiction to regulate related lien-enforcement proceedings.
3. Whether the injunction was improperly broad insofar as it purported to restrain foreign proceedings and foreign vessel arrests without the findings required for a foreign anti-suit injunction.

## Decision

- The court affirmed that statutory interpleader jurisdiction existed because the adverse claims were “inextricably intertwined” as competing demands on the same payment obligation, consistent with the remedial purpose of § 1335 to prevent multiple liability and duplicative litigation.
- The court held that by initiating interpleader addressing asserted **in rem** claims and posting adequate security, the vessel operator consented to the court’s jurisdiction over its interests, supporting injunctive relief to protect the interpleader proceeding.
- The court remanded for reconsideration of the injunction’s foreign scope, directing the district court to either remove any foreign reach or retain it only after applying the governing foreign anti-suit injunction test and making specific findings.

## Legal Principles

- Statutory interpleader under 28 U.S.C. § 1335 is construed liberally to allow a stakeholder to resolve adverse claims to a single obligation or fund and to avoid exposure to multiple liability, even when claimants proceed under different legal theories.
- Claims framed as **in rem** maritime lien enforcement may be treated as adverse claims to the same underlying payment obligation when the arrests function to secure payment of that debt.
- A stakeholder may consent to jurisdiction for purposes of managing competing claims by initiating interpleader and posting adequate security, permitting the court to regulate overlapping proceedings necessary to protect the interpleader res.
- Although 28 U.S.C. § 2361 authorizes injunctions to protect interpleader jurisdiction, any foreign anti-suit component requires a separate, explicit analysis under the controlling circuit test for foreign anti-suit injunctions (including party/issue identity and equitable factors such as threats to jurisdiction or policy evasion).

## Conclusion

The court approved using statutory interpleader and a domestic restraining order to consolidate competing demands for a single bunker-payment obligation, including claims pursued through maritime vessel arrests, but required the district court to justify any restraint of foreign proceedings through specific findings under the foreign anti-suit injunction standard.


Hapag-Lloyd Aktiengesellschaft v. U.S. Oil Trading LLC, 814 F.3d 146 (2d Cir. 2016)