## Facts

- New Jersey Sports Productions, Inc., doing business as Main Events (Main Events), arranged for heavyweight boxer Oliver McCall to participate in a championship bout held in Nevada.
- McCall’s agreed purse was $3,075,500, with payment to be made through a New Jersey bank.
- The bout ended after McCall stopped competing during the fight; Main Events took the position that McCall’s conduct breached the bout agreements and that McCall was not entitled to be paid.
- Main Events asserted that it faced actual or expected competing demands to the purse (or its net amount) from multiple parties, including McCall, Don King Productions, Inc. (DKP), and others connected to the event and McCall’s contractual relationships.
- Nevada’s athletic regulator, the Nevada Athletic Commission (NAC), also asserted authority under Nevada law and the Nevada commission bout contract to control whether McCall could be paid and to direct disposition of the purse, and disciplinary proceedings against McCall were pending in Nevada.
- Main Events filed suit in the U.S. District Court for the District of New Jersey and sought interpleader relief, asking to deposit approximately $3,003,923.04 (plus interest) into the court registry and to require all claimants to litigate their rights to that fund in a single action.
- Main Events did not clearly specify whether it was proceeding under statutory interpleader (28 U.S.C. § 1335) or rule interpleader (Fed. R. Civ. P. 22).
- DKP opposed the requested interpleader relief, arguing (among other things) that New Jersey was an improper forum and that interpleader was improper because there were not truly adverse claimants or because Nevada proceedings should control.
- McCall opposed the motion on personal-jurisdiction grounds, contending the New Jersey federal court lacked authority over him given that the bout and much of the underlying conduct occurred in Nevada.

## Issues

1. Whether Main Events, as a stakeholder facing competing or anticipated claims to a single boxing purse, was entitled to interpleader relief and permission to deposit the funds into the court registry.
2. Whether the District of New Jersey could exercise personal jurisdiction over McCall in light of the purse’s New Jersey payment arrangements and the parties’ contractual dealings.
3. Whether venue and forum were proper in New Jersey despite the Nevada location of the bout and the existence of NAC disciplinary proceedings.
4. Whether the court could restrain other actions affecting the purse while allowing the NAC’s disciplinary action against McCall to proceed.

## Decision

- The court granted Main Events’ motion to proceed with interpleader relief concerning the purse.
- The court authorized Main Events to deposit $3,003,923.04 (plus accrued interest) into the court registry.
- The court directed claimants to file and litigate their claims to the fund in the District of New Jersey.
- The court restrained other actions affecting the interpleaded funds, while expressly allowing the NAC’s disciplinary proceeding against McCall to continue.
- The court rejected McCall’s challenge to personal jurisdiction and rejected DKP’s objections based on venue and the asserted effect of Nevada proceedings.

## Legal Principles

- Interpleader is available to a stakeholder exposed to multiple liability on a single fund when rival claimants assert, or are reasonably expected to assert, competing rights to that fund; the stakeholder need not wait until every claimant files suit.
- A party may pursue interpleader under Fed. R. Civ. P. 22 using an independent basis for subject-matter jurisdiction (such as diversity jurisdiction under 28 U.S.C. § 1332), even if the pleading does not perfectly label the interpleader mechanism at the outset.
- Personal jurisdiction may exist where a defendant’s voluntary contractual dealings and contemplated performance create sufficient contacts with the forum, including where payment obligations are tied to the forum and the defendant could reasonably foresee litigation there over the payment.
- Venue in an interpleader-type dispute may be proper where the stakeholder resides and where the disputed fund is held or payable, particularly when the requested relief is aimed at resolving competing demands to a single res in one proceeding.
- A federal court overseeing an interpleaded fund may issue injunctive relief to protect the fund and prevent inconsistent judgments or duplicative litigation over the same money, and it may tailor that relief to avoid interference with separate regulatory or disciplinary proceedings.

## Conclusion

The District of New Jersey allowed Main Events to deposit the contested boxing purse into the court registry and required claimants to litigate entitlement to that money in one forum, holding that New Jersey was a proper place for the dispute and that the court had personal jurisdiction over McCall, while crafting its restraint of other lawsuits to leave the Nevada athletic commission’s disciplinary case against McCall unaffected.


New Jersey Sports Productions, Inc. v. Don King Productions, Inc., 15 F.Supp.2d 534 (1998)