Johnson v. Mayor &C. of Carrollton

There are two types of interpleader available in this state; that provided by CPA § 22 (Code Ann. § 81A-122), and that provided by Code Ann. § 37-1503. One is not entitled to proceed under the latter unless four requirements are met: “(1) The same thing, debt, or duty must be claimed by both or all of the parties against whom the relief is demanded; (2) all their adverse titles or claims must be dependent, or be derived, from a common source; (3) the plaintiff must not have or claim any interest in the subject matter; (4) the plaintiff must have incurred no independent liability to either of…