Temple v. Synthes Corp.

Brief Fact Summary.

Petitioner sued Respondent in federal court. Respondent filed a motion to dismiss, arguing Petitioner had failed to join other necessary parties to the lawsuit under Rule 19.

Synopsis of Rule of Law.

Rule 19 does not require that all joint tortfeasors be named as defendants in a single lawsuit.

Facts.

Temple (Petitioner) sued Synthes Corp. Ltd. (Respondent) in federal court under diversity jurisdiction for defective design and manufacturing of a plate and screw device implanted in Petitioner’s spine. Separately, Petitioner sued the doctor that performed the surgery and the hospital where the surgery occurred in state court for malpractice and negligence. Respondent filed a motion to dismiss, arguing that Petitioner had failed to join the doctor and hospital in the federal lawsuit as necessary parties under Rule 19.

Issue.

Must the Petitioner join the hospital and doctor to the federal lawsuit, under Rule 19?

Held.

No, the Petitioner is not required to join additional parties to the federal lawsuit. The decision of the Fifth Circuit Court of the Appeals is reversed and remanded.

Discussion.

The Court determined that joint tortfeasors are not necessary parties under Rule 19. While Petitioner could join the hospital and doctor to the federal lawsuit, it was not required.