Mastercard International, Inc. v. Visa International Services Ass’n, Inc.

Citation. 471 F.3d 377 (2d Cir. 2006)

Brief Fact Summary.

Plaintiff sued Defendant for breach of contract. Visa argued that it should be joined to the case under Rule 19(a) and the case dismissed for lack of diversity jurisdiction.

Synopsis of Rule of Law.

Under Rule 19(a), a party is necessary and indispensable if the court cannot grant relief in their absence, their interest is at risk of prejudice, and the original parties are at risk of inconsistent rulings.

Facts.

Mastercard (Plaintiff) sued Federation Internationale de Football Association (Defendant) for breach of contract. Plaintiff argued that Defendant breached the contract’s first right to acquire after offering exclusive sponsorship rights for all of Defendant’s World Cup competitions to Visa, and moved for a preliminary injunction. Visa argued that it was a necessary and indispensable party under Rule 19(a) and that the case should be dismissed because joinder would defeat diversity jurisdiction.

Issue.

Did the district court properly deny Visa’s motion to join as a necessary and indispensable under Rule 19(a)?

Held.

Yes, the district court properly determined that Visa was not a necessary party under Rule 19(a).

Discussion.

The Court found that the district court did not abuse its discretion in ruling that Visa was not a necessary and indispensable party under Rule 19(a). While Visa has an interest in the outcome of the case, the Court determined that Visa’s absence from the litigation would not prevent the court from granting complete relief between Plaintiff and Defendant nor prevent future consistent litigation between Visa and the Defendant regarding Visa’s contract.