Plaintiff jeweler that entered into a contract where Defendant Mall agreed not to allow more than two other jewelers to be present in the mall. Defendant signed a lease with a third jeweler and Plaintiff sought injunctive relief to keep Defendant from creating the lease with the third jeweler. Defendant moved to dismiss Plaintiff’s claim for Plaintiff’s failure to join that third jeweler as an indispensable party.
A party does not become indispensable to an action to determine rights under a contract just because that party’s rights under a separate contract will be affected by the result of the action.
Plaintiff and Defendant entered into a written contract for Defendant to not allow more than two other jewelers in the shopping center. Defendant thereafter signed a contract with two other jewelers in the mall, and then a third jeweler named Lord’s. Plaintiff Helzberg filed a complaint in federal court based on diversity jurisdiction seeking injunctive relief to stop Defendant Valley West from breaching the contract and signing a lease with the third jeweler. Defendant Valley West moved to dismiss for Plaintiff’s failure to join Lord’s as a party. The district court denied the motion and granted Plaintiff Helzberg’s preliminary injunction. Defendant West Valley appealed.
Does a person become indispensable to an action because their rights under a separate contract will be affected as a result of the action?
No, a person does not become indispensable to an action because their rights under a separate contract will be affected as a result of the action. The judgement of the district court is affirmed.