Abstract
The collapse of O.W. Bunker has led to a frenzy of actual and threatened vessel arrests and delays, and vessel owners have faced demands for double payment. The United States Court of Appeals for the Second Circuit for the first time have encountered the issue of whether jurisdictions lies interpleader involving in rem actions. The Second Circuit held that the in person am claims against the vessel owners and the in rem claims against the vessels were merely alternative procedural devices to obtain the same relief and therefore the court has subject matter jurisdiction over the interpleader actions. For vessel owners, the decisions in all such cases are notable because it means that vessel owners can utilize interpleader actions to protect themselves from multiple payments and from the risk of ship arrest arising from the O.W. Bunker collapse.
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