| Venue: | SCOTUS |
| Facts: | Temple has some back surgery. The device that got implanted breaks, and some screws are loose in there. LaRocca is the doctor, and St. Charles General Hospital is the operating theater. Synthes made the device. |
| Posture: | Suit in US district court for E.D. LA, relying on diversity. There's a state administrative proceeding against LaRocca and the hospital as well. When that concludes Temple sues them both in state court. Synthes moves to dismiss for failure to join necessary parties. Dismissed. On appeal, 5th Cir. affirms: the judge did not abuse his discretion in issuing the dismissal. |
| Issue: | Was it error to label joint tortfeasors as indispensible parties under Rule 19(b) and dismiss on that basis? |
| Holding: | Yes. Reversed. |
| Rule: | Nothing in Rule 19 changes the long-standing rule that not all joint tortfeasors have to be named in the same lawsuit. |
| Reasoning: | These are permissive parties. They certainly could be joined (and that's the normal practice), but judicial economy isn't so dominant a concern that we force people to join just because they can. |
| Dicta: | |