Camacho v. Major League Baseball
Facts
Plaintiffs alleged that Major League Baseball prevented Pesqueira from training and playing with the Boston Red Sox on the ground that he belonged to a Mexican League team and was on the Mexican League reserve list. Plaintiffs contended that the supposed contracts between Pesqueira and the Diablos Rojos (Red Devils) were invalid because Pesqueira was a minor when they were executed or because the signatures were fraudulent. The complaint sought, among other relief, a declaration whether Pesqueira was bound to the Red Devils. The Red Devils and the Mexican League were not joined as parties.
Issue
Whether the Red Devils and the Mexican League were required parties under Rule 19 in an action whose central premise was that Pesqueira's alleged contracts with the Red Devils were invalid, and if so whether the action had to be dismissed because joinder was not feasible and those absent parties were indispensable.
Rule
Under Rule 19, a court asks whether an absent party is necessary, whether joinder is feasible, and if not, whether the absent party is indispensable. A party is necessary if complete relief cannot be granted in its absence, if it has a legally protected interest that may be impaired or impeded by the suit, or if proceeding without it creates a substantial risk of multiple or inconsistent obligations; and a party to a contract is necessary, and if joinder is not feasible, indispensable, in litigation seeking to invalidate or decimate that contract.
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