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.
As potential joint tortfeasors with Synthes, the doctor and the hospital were merely permissive parties.View Full Point of Law
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.