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Mitchell v. Hood

Citation. 614 Fed.Appx. 137 (5th Cir. 2015)
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Brief Fact Summary.

Plaintiff, a judicial candidate, sued Defendant for defamation associated with a postcard that was sent to voters. Defendant impleaded Judge Anderson-Trahan under Rule 14 for putting his name on the postcard.

Synopsis of Rule of Law.

For an impleader claim to be proper under Rule 14, the third-party’s liability must be contingent on the outcome of the claim against the defendant.


Judicial candidate Kiana Mitchell (Plaintiff) sued Brett Hood (Defendant) for defamation after a postcard with Defendant’s name was sent to voters accusing Plaintiff of violently attacking a pregnant woman. Defendant impleaded the judge who won the election, Judge Anderson-Trahan, under Rule 14. Defendant sought personal damages from Judge Anderson-Trahan for fraud, misrepresentation, abuse of right, and injury to personal and professional reputation. Judge Anderson-Trahan moved to dismiss the case.


Was Judge Anderson-Trahan properly impleaded under Rule 14?


No, Judge Anderson-Trahan was not properly impleaded. The case is remanded.


Here, liability and subsequent damages relating to Plaintiff’s defamation claim against Defendant were not tied to Defendant’s claims of fraud, misrepresentation, abuse of right, and reputation against Judge Anderson-Trahan.

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