Temple v. Synthes Corp.
498 U.S. 5, 111 S. Ct. 315, 112 L. Ed.2d 263 (1990)
Temple lived in Mississippi.
He had back surgery in Louisiana performed by LaRocca. LaRocca used
surgical screws made by Synthes, which was a Pennsylvania corporation.
The screws broke and Temple
was injured. He sued Synthes in Federal Court under diversity
jurisdiction. At the same time he
sued LaRocca (and the hospital) in Louisiana State Court.
Synthes argued that under Rule
19, Temple was required to join
LaRocca into the Federal lawsuit.
Synthes could have also
attempted to join LaRocca into the
Federal lawsuit themselves by using Rule 14(a).
The Federal Trial Court
ordered Temple to join LaRocca as a
co-defendant or risk dismissal. When he failed to do so, the Court
dismissed the case. Temple appealed.
The Federal Appellate Court
affirmed.
The Federal Appellate Court
found that the claims overlapped and it would be prejudicial to try the
cases separately.
Synthes was going to blame
LaRocca and LaRocca was going to blame Synthes.
The US Supreme Court reversed
and remanded for trial.
The US Supreme Court found
that it is not necessary for all joint tortfeasors to be named as
defendants in a single lawsuit.
Basically, although it would
be efficient and convenient to have a single lawsuit, LaRocca was not an indispensable
party. You could proceed with each
lawsuit independently.
Rule 19 is for situations such as where the decision
of the court might require binding of a party who was not in the court.
In this case, no verdict against Synthes could possibly bind LaRocca to
anything, so there is no requirement for joining.
LaRocca and Synthes are permissive
parties.
See Haas v. Jefferson
National Bank (442 F.2d 394 (1971)) for an example of
where Rule 19 is
required.
Btw, the Supreme Court issued
this unanimous opinion solely on the basis of the petition for certiorari.
They were so sure of the answer, they didn't bother to schedule an oral argument or
get a briefing on the merits.