Airborne Freight Corp. v. United States

IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT _______________ m 98-60692 _______________ AIRBORNE FREIGHT CORPORATION, Plaintiff-Appellee, VERSUS UNITED STATES OF AMERICA, ET AL, Defendants, R.R. MORRISON & SON, INC., Defendant-Appellant. _________________________ Appeal from the United States District Court for the Southern District of Mississippi _________________________ November 23, 1999 Before GARWOOD, SMITH, and facts, we vacate and remand for purposes of BENAVIDES, Circuit Judges. dismissal and of dissolution of the injunction. JERRY E. SMITH, Circuit Judge: I. R.R. Morrison & Son, Inc. (“Morrison”), Airborne Freight Corporation (“Airborne”) seeks dismissal of this interpleader suit and seeks status as stakeholder to interplead dissolution of an injunction, on grounds of jur- Morrison and the Internal Revenue Service isdiction and equity. Because we agree with (“IRS”) to compete for claims to $106,826.36 Morrison that the district court lacked (the “stake” or “fund”) that Airborne owed to jurisdiction to hear an interpleader on these GTB Services, Inc. (“GTB”), the insolvent debtor of Airborne, Morrison, and the IRS. ture of an interpleader” rather than as a true After depositing the disputed stake into the interpleader, because Airborne pleaded its own registry of the court, Airborne sought interest in the stake. dismissal from the interpleader action and an injunction to prevent Morrison from executing After final judgment in the prior suit, a money judgment awarded by another court denying Airborne’s interest in the stake, against Airborne. The injunction issued. Airborne disclaimed that interest, filed a mo- tion to be dismissed from the interpleader ac- Airborne and GTB were parties to various tion, and requested an injunction against contracts in which GTB agreed to provide Morrison. The interpleader court concluded cartage services to Airborne. In an unrelated that the elements of statutory interpleader had transaction, GTB, to secure credit extended to been met and noted that absent an injunction it by Morrison for the purchase of fuel, gave prohibiting Morrison from executing on the Morrison a security interest in its accounts re- prior judgment, Airborne could be subjected to ceivable due from Airborne under the cartage double liability. The court then dismissed Air- contracts. borne and enjoined Morrison from executing on its earlier judgment. Morrison appeals, GTB defaulted on its payments to asking that we dismiss the interpleader action Morrison, and as assignee of payments owed and dissolve the injunction.1 to GTB by Airborne under the cartage contracts, Morrison sought to enforce its se- II. curity interest and gave notice to Airborne. A. Airborne refused to pay, claiming it had The issue is whether the district court had retained a portion of the accounts payable to jurisdiction to permit Airborne to maintain an GTB under a right of setoff in the cartage interpleader suit involving Morrison and the contracts. IRS. We review a district court’s assertion of original jurisdiction de novo, applying the same Morrison sued Airborne, ultimately obtain- standard as did the district court. McClelland ing a $50,000 final, non-appealable general v. Gronwaldt, 155 F.3d 507, 511 (5th Cir. money judgment. Both before and after that 1998) (citations omitted). judgment, the IRS gave statutory notice to Airborne and Morrison of a tax lien against B. GTB in excess of the disputed fund. The IRS The central prerequisite for a “true” did not, however, attempt to intervene in the interpleader actionSSone in which the plaintiff action between Airborne and Morrison. is a real stakeholder rather than a claimant2SSor for an action in the nature of After the court (the “prior district court”) interpleader, in which the plaintiff-stakeholder had issued a memorandum opinion, but before it had issued a final order, Airborne filed the instant interpleader action, attempting to join Morrison and the IRS as competing claimants 1 The IRS is not participating in this appeal. and depositing the disputed fund into the regis- try of the court. This action arose “in the na- 2 See Texas v. Florida, 306 U.S. 398, 406-07 (1939) (defining “strict” or “true” interpleader). 2 also makes a claim to the stake,3 is that the judgment against Airborne.6 plaintiff-stakeholder runs the riskSSbut for determination in interpleaderSSof multiple We do not collaterally review and overturn liability when several claimants assert rights to orders of other courts that have become final a single stake.4 The prerequisite arises without and unappealable, even if we fear the order regard to whether the plaintiff-stakeholder may have issued in error.7 Instead, we value attempts to invoke “rule” interpleader or finality.8 It follows, then, that Morrison’s “statutory” interpleader.5 Interpleader should be employed for “the avoidance of the burden 6 of unnecessary litigation or the risk of loss by The order of the first court cannot reasonably the establishment of multiple liability when be read as anything but a general judgment against Airborne. Most importantly, the order reads on its only a single obligation is owing.” Texas v. face as a general judgment, satisfiable by any as- Florida, 306 U.S. at 412. sets held by Airborne. That court refused to enter a final order submitted by Airborne that would Such is not the situation here. Airborne have limited Morrison’s collection rights to the asserts that Morrison’s claim against it must be accounts-payable fund held by Airborne; the court drawn from the stake it has tendered to the refused Airborne’s motion to consolidate the IRS’s court. Morrison, however, correctly notes claim against the fund, because the court thought that the final order that issued from the prior the claims of Morrison and the IRS “both . . . seek court was emphatically not a judgment money from Airborne, but the similarity in the collectable against the fund held by Airborne actions ends there”; and the court made other, and owed to GTS, but was rather a general similar manifestations of intent. It may well be argued that, in rejecting an overt opportunity to issue a judgment against the fund in favor of issuing a judgment against Airborne 3 See id. (defining actions in the nature of generally, the prior court erred. Airborne should, interpleader). in fact, have argued exactly that, on appeal of the prior action. Instead of appealing, however, it 4 See White v. FDIC, 19 F.3d 249, 251 (5th allowed the general judgment against it to become Cir. 1994) (defining interpleader as a “procedural final and unappealable and focused its remedial device which entitles a person holding money or efforts on the interpleader action now before us. property, concededly belonging at least in part to 7 another, to join in a single suit two or more persons See In Re Teal, 16 F.3d 619, 622 (5th Cir. asserting mutually exclusive claims to the fund”). 1994) (citing Federated Dep’t Stores, Inc. v. Moitie, 452 U.S. 394, 401 (1981)) (noting “the 5 See FED. R. CIV. P. 22 (allowing “plaintiff [to] well-known rule that a federal court may not abro- join[] defendants . . . when their claims are such gate principles of res judicata out of equitable con- that the plaintiff is or may be exposed to double or cerns” and that erroneous legal conclusions do not multiple liability”); 28 U.S.C. § 1335 (granting alter the res judicata effect of a final judgment). original jurisdiction to the district courts in “any 8 civil action of interpleader or in the nature of See Bennett v. Commissioner, 113 F.2d 837, interpleader” “if two or more adverse claimants . . 839 (5th Cir. 1940), explaining that . are claiming or may claim to be entitled to such money or property” as shall have been pleaded into [r]es judicata is a principle of peace. Under court). (continued...) 3 claim is against Airborne, not the stake, and entitled either claimant to ignore the res that Morrison cannot be forced to attempt to entirely and satisfy its claims out of the general satisfy its general judgment against the stake. property of the stakeholder. See id. Airborne attempts to defeat this argument Similarly, in Mutual Life, the relevant by relying, along with the district court, on a claimants held general judgments against a line of precedent, including Treinies v. debtor and had filed (or perfected) Sunshine Mining Company, 308 U.S. 66 garnishment and attachment suits against a (1939), and Mutual Life Ins. Co. v. Bohart, stake (an insurance settlement payable to the 743 F.2d 313 (5th Cir. 1984), that they have debtor) held by an insurance agency for the read to hold that “a stakeholder’s right to debtor. See Mutual Life, 743 F.2d at 316-18. interplead is not necessarily defeated by the The insurance agency interpleaded the fact that an interpleaded claimant has an judgment-holding claimants and enjoined their outstanding judgment against the stakeholder.” attempts to satisfy adverse claims against the In so reading, though, the district court and stake so that those adverse interests in the Airborne have misinterpreted these precedents. stake could be determined in a single litigation, and without creating overlapping liabilities on the part of the stakeholder. Id.9 No general In Treinies, for instance, the interpleaded judgments had issued against the stakeholder. claimants held outstanding judgments against the stakeSSin that case, shares of stock, all of The cases cited by the district court and by which had been adjudged the property of one Airborne, then, establish only the proposition claimant by an Idaho court, and half of which that a judgment against a stake does not had been adjudged the property of another automatically estop the stakeholder from claimant by a Washington court. See Treinies, bringing an interpleader action. We find no 308 U.S. at 68-69. Each judgment fault with this holding but are not faced with represented a stake in a fixed res that could such a situation. not satisfy both claimants; neither judgment Rather, the circumstance here is that a party is a general-judgment creditor of a general- 8 (...continued) judgment debtor, which debtor happens to its influence an end is put to controversies. hold a stake in which a third party claims an Parties and their privies are made to abide interest. Were the general-judgment debtor definitive and final judgments and litigations are concluded. Res judicata rests on a rule of public policy designed to put an end to 9 mere contentious litigations. Under that rule The issue in Mutual Life was whether the an issue once finally settled by the judgment insurer had mis-distributed a portion of the stake of a court of competent jurisdiction, remains prior to the advent of the interpleader action. To settled. Public policy dictates that there be the extent that it had, it would have been required an end of litigation; that those who have to “re-fill” the stake; it was not, however, generally contested an issue shall be found by the liable to the claimants for their general judgments result of the contest; and that matters once against the debtor, and no general judgments were tried shall be considered forever settled as ever filed against the insurer in favor of the between the parties. claimants. See Mutual Life, 743 F.2d at 316-18. 4 bankrupt or otherwise bereft of funds other than those in the stake, then we would not thwart the claimant’s efforts to satisfy his gen- eral judgment as best he could from the value of the stake, as a participant in the interpleader action. We cannot, however, force a judgment creditor who holds a general judgment against a judgment debtor to contest with claimants who hold an interest only in a stake held by the judgment debtor, if that judgment creditor elects to satisfy its judgment out of other as- sets held by the fully solvent judgment debtor. The judgment creditorSSMorrisonSShad declined to attempt to satisfy its claim out of the stake held by Airborne and pleaded into court. Morrison prefers to satisfy its general judgment out of other assets held by Airborne, which assets are not subject to any contest. Meanwhile, Airborne has acknowledged the actions of the prior court at least insofar as to have disclaimed any interest in the stake Airborne has interpleaded. This leaves only one claimant to the stake: the IRS. If there is only one claimant to a stake, then by definition there are not overlapping and ad- verse claims to it. Therefore, the central prerequisite of interpleader has not been met, interpleader cannot lie, and the injunction issued pursuant to the grant of interpleader cannot stand. Accordingly, the judgment and injunction are VACATED, and this matter is REMANDED with instruction to dismiss the interpleader action. 5