concurring.
I join the excellent opinion of Mr. Justice Stewart and write simply to emphasize his conclusion that, in light of Edelman v. Jordan, 415 U. S. 651 (1974), this Court’s decision in Worcester County Trust Co. v. Riley, 302 U. S. 292 (1937), no longer can be regarded as a bar against the use of federal interpleader by estates threatened with double death taxation because of possible inconsistent adjudications of domicile.
As Professor Zechariah Chafee, the father of federal statu*616tory interpleader, pointed out: “It is our federal system which creates the possibility of double taxation. Somewhere within that federal system we should be able to find remedies for the frictions which that system creates.” Federal Inter-pleader Since the Act of 1936, 49 Yale L. J. 377, 388 (1940). The Worcester County Court, much to Professor Chafee’s regret, 49 Yale L. J., at 388, held that the Eleventh Amendment precluded resort to federal interpleader as a remedy for the particularly unfair “friction” that can result from conflicting adjudications of domicile in death taxation cases.
But as noted by Mr. Justice Stewart, ante, at 608-609, n. 10, Worcester County has been effectively undercut by subsequent developments. Edelman made it clear that the Eleventh Amendment bars only suits “by private parties seeking to impose a liability which must be paid from public funds in the state treasury,” 415 U. S., at 663, and not actions which may have “fiscal consequences to state treasuries . . . [that are] the necessary result of compliance with decrees which by their terms [are] prospective in nature,” id., at 667-668, at least in a case such as this, where the very controversy is a result of our federal system. An interpleader action to prevent competing States’ taxing officials from levying death taxes on the basis of possible inconsistent adjudications of domicile unquestionably would fall into the latter category. Accordingly, it would appear that resort to federal inter-pleader no longer is proscribed by the Eleventh Amendment in this situation.