Manufacturers and Traders Trust Company v. Akers
8:16-cv-03346
D. MarylandAug 18, 2017Background
- Del Conca transferred $302,662.69 which was credited to Nathaniel Akers' account at M&T; Del Conca later claimed the transfer was fraud and sought recovery.
- M&T, the stakeholder, initiated this interpleader action joining Del Conca and Akers to resolve competing claims to the Funds.
- The Court previously ordered M&T to deposit the disputed Funds with the Court Clerk, awarded M&T $9,092.60 in attorneys’ fees/costs from the deposit, and discharged M&T from further liability regarding the Funds.
- Akers was served but never appeared, answered, or otherwise defended; the Clerk entered default against Akers.
- Del Conca moved for default judgment against Akers to resolve entitlement to the remaining deposited Funds.
- The Court granted Del Conca’s motion, ordered disbursement of the remaining funds to Del Conca, and enjoined Del Conca and Akers from further proceedings against M&T concerning the Funds.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a default judgment can be entered against a served interpleader defendant who failed to appear | Del Conca: default judgment is proper; Akers forfeited any claim by failing to respond | Akers: no response or asserted position (no appearance) | Court: default judgment granted against Akers |
| Whether the remaining deposited Funds should be disbursed to Del Conca after default | Del Conca: as the only claimant who defended, she is entitled to the funds | Akers: no claim preserved due to default | Court: disburse remaining Funds to Del Conca |
| Whether the stakeholder (M&T) remains liable after depositing Funds and receiving awarded fees | Del Conca: M&T should be discharged after deposit and fee award | M&T: sought discharge (already granted) | Court: M&T discharged from further liability regarding the Funds |
| Whether claimants are enjoined from further proceedings against the stakeholder | Del Conca: seeks final resolution and injunction to bar further suits against M&T | Akers: no response | Court: Del Conca and Akers enjoined from instituting/prosecuting further proceedings against M&T regarding the Funds |
Key Cases Cited
- Arcade Textiles, Inc. v. Security Ins. Co. of Hartford, [citation="40 F. App'x 767"] (4th Cir. 2002) (describing interpleader as device for a stakeholder to bring competing claimants into a single action)
- High Tech Prods., Inc. v. United States, 497 F.3d 637 (6th Cir. 2007) (discussing the two-stage nature of interpleader: stakeholder discharge then claimant litigation)
- Moradi v. United States, 673 F.2d 725 (4th Cir. 1982) (Rule 55 permits default judgment where a defendant fails to plead or otherwise defend)
- Nationwide Mut. Fire Ins. Co. v. Eason, 736 F.2d 130 (4th Cir. 1984) (noting that a defaulting interpleader defendant forfeits any claim to the funds)