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Temple v. Synthes Corp.

Supreme Court of the United States · 1990 · Civil Procedure

Civil Procedurejoindercompulsory joinderjoint tortfeasorsRule 19Rule 19Rule 19(a)Rule 19(b)

Facts

Temple underwent spinal surgery in which a plate-and-screw device manufactured by Synthes was implanted in his back. After the surgery, the device's screws broke off inside his back. Temple sued Synthes in federal court alleging defective design and manufacture, while separately proceeding against Dr. LaRocca and the hospital for malpractice and negligence in Louisiana. Synthes did not implead the doctor or hospital under Rule 14(a), but instead moved to dismiss for failure to join them under Rule 19.

Issue

Whether alleged joint tortfeasors such as the doctor and hospital were required parties under Rule 19 so that Temple's federal action against Synthes could be dismissed for failure to join them. More specifically, the question was whether they could be treated as indispensable parties whose absence justified dismissal with prejudice.

Rule

It is not necessary for all joint tortfeasors to be named as defendants in a single lawsuit. Potential joint tortfeasors with usual joint-and-several liability are merely permissive parties under Rule 19(a), and if Rule 19(a)'s threshold requirements are not satisfied, no Rule 19(b) indispensability analysis is necessary.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nina Patel, an Illinois resident, sues Great Lakes Lift Systems, a fictional Michigan manufacturer, in federal court in Chicago alleging that a warehouse hoist was defectively designed and injured her. In a separate Illinois state action, she sues her supervisor, Omar Vega, and Riverbend Storage Center, a fictional company in Joliet, for negligent training and unsafe workplace practices arising out of the same accident.

Great Lakes moves to dismiss under Rule 19, arguing that Omar and Riverbend must be joined because all claims arise from the same injury. How should the court rule?

Explanation. The motion should be denied. The governing rule is that alleged joint tortfeasors with usual joint-and-several liability are merely permissive parties, not parties required to be joined under Rule 19(a). Because the Rule 19(a) threshold is not satisfied, the court should not proceed to Rule 19(b). Separate litigation arising from the same injury does not itself make other alleged tortfeasors compulsory parties. (Derived from Temple v. Synthes Corp. (1990).)