Temple v. Synthes Corp

Brief Fact Summary. The Petitioner, Temple (Petitioner), underwent surgery in October 1986 during which a plate and screw device was implanted in his lower spine. Petitioner sued the Respondent, Synthes Corp. (Respondent), a manufacturer in federal court and the doctor who installed the device in state court. The manufacturer moved to dismiss the federal court action for failing to join necessary parties.

Synopsis of Rule of Law. Federal Rule of Civil Procedure (FRCP) Rule 19 does not require joining all potential tortfeasors to be named as defendants in a single lawsuit.

Facts. Petitioner underwent surgery in October 1986 during which a plate and screw device was implanted in his lower spine. The device was manufactured the Respondent. Dr. S. Henry LaRocca (Dr. LaRocca) performed the surgery in New Orleans, Louisiana. Following the surgery, the device’s screws broke off inside Petitioner’s back.
Petitioner filed suit against Respondent in federal district court, alleging defective design and manufacture of the device. At the same time, Petitioner filed a state administrative proceeding against Dr. LaRocca and the hospital for malpractice and negligence. At the conclusion of the state proceeding, Petitioner filed suit against Dr. LaRocca and the hospital in Louisiana state court.
Respondent did not attempt to bring Dr. LaRocca and the hospital into the suit by means of a third party complaint, but instead filed a motion to dismiss Petitioner’s federal suit for failure to join necessary parties under FRCP Rule 19. Following the motion, the district court ordered Petitioner to join the doctor and hospital as defendants or risk dismissal. When Petitioner failed to join them, the court dismissed the suit with prejudice. Petitioner appealed, and the Court of Appeals for the Fifth Circuit affirmed. The Supreme Court of the United States (Supreme Court) granted certiorari.

Issue. Whether a court should dismiss an action for failing to join all potential tortfeasors relating to the action in a single suit.

Held. No. The judgment of the court of appeals was reversed.
It is not necessary to join all potential tortfeasors to be named as defendants in a single lawsuit. As potential tortfeasors with Respondent, Dr. LaRocca and the hospital were merely permissive parties. The Court of Appeals erred by failing to hold that the district court abused its discretion in ordering them joined as defendants and in dismissing the action.

Discussion. Students should realize that this was a per curiam decision of the Supreme Court. Per curiam decision’s usually signify that the court believes the principles are clear beyond doubt and require no extended discussion.