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ARMOUR FERTILIZER WORKS, an Illinois corporation, has a claim against Sanders, a citizen and resident of Texas. It contemplates an action at law to reduce this claim to judgment. Before bringing suit it makes an investigation to find out whether or not Sanders has any property on which it could levy an attachment or execution to satisfy a judgment. It finds that he has no tangible propertysuch as cattle, land, automobiles, etc.-subject to attachment or execution. It does discover, however, that the Garnishee Company, a corporation organized under the laws of Connecticut and lawfully transacting business in Illinois as well as in Connecticut, owes Sanders a simple contract debt. Sanders may have a valuable asset in this chose in action against the Garnishee Company. By assignment he could dispose of it for value. In short it is "property." In the absence of some prohibition imposed by some competent law some method should exist whereby Armour Fertilizer Works could compel the application of the proceeds of Sanders' claim against the Garnishee Company to the satisfaction of any judgment that Armour Fertilizer Works might recover against him. By legal process Armour Fertilizer Works should be able to collect directly the amount the Garnishee Company is adjudged to owe Sanders and apply such collection in partial or total satisfaction of the amount he is adjudged to owe Armour Fertilizer Works. Conceivably the law might permit Armour Fertilizer Works to bring an action against Sanders in Texas, perhaps the only state in which a personal judgment could be recovered against him. Contemporaneously with the institution of this action, on the petition of Armour Fertilizer Works filed in Connecticut or Illinois against the Garnishee Company, the latter would be enjoined from paying its debt to Sanders pending the outcome of the Texas action. If Armour Fertilizer Works recovered judgment against Sanders in the Texas action, the Texas court would order such judgment satisfied out of the proceeds of the debt that the court in the Connecticut or Illinois suit might adjudge the Garnishee Company to owe

The Federal Interpleader Act and Conflict of Laws in Garnishment