Temple v. Synthes Corp., Ltd. – Case Brief Summary
Summary of Temple v. Synthes Corp., Ltd., 498 U.S. 5, 111 S. Ct. 315, 112 L. Ed. 2d 263 (1990).
Temple (P) underwent back surgery and a plate and screw were inserted into his spine. The screws broke off inside his spine and Temple sued Synthes (D), the manufacturer of the plate and screw, for products liability in federal court. Temple then sued the doctor and the hospital for negligence and malpractice in state court.
Synthes filed a motion to dismiss under FRCP 19 on the grounds that Temple failed to join all the necessary parties. The trial court gave Temple an additional twenty days to join the doctor and the hospital and dismissed the case with prejudice when he failed to comply.
Temple appealed and the court of appeals affirmed, holding that FRCP 19 calls for mandatory joinder of necessary parties in the interest of judicial efficiency. The court reasoned that the manufacturer might claim that the doctor and the hospital were negligent and the device was not defective. Alternatively, the doctor and the hospital might claim that they were not negligent and that the device was defective. Temple appealed.
Are joint tortfeasors indispensable parties under FRCP 19(a)?
Holding and Rule
No. Joint tortfeasors are not indispensable parties under FRCP 19(a).
The court held that this is a long-standing rule of law and is not changed by Rule 19. Under the Advisory Committee notes to Rule 19(a), a tortfeasor with usual joint and several liability is merely a permissive party to an action against another with like liability.
Reversed and remanded.
Compulsory joinder is required in suits in which joint rights and liabilities are held by more than one party, if granting relief would affect the rights of parties not in the lawsuit. Joint tortfeasors are permissive parties. Permissive parties may be joined in the same suit. Indispensable parties must be joined in the same lawsuit.
All joinder rules are matters of public policy and equitable fairness to the parties before the court. Courts and society are interested in efficiency in the court system and the parties to the lawsuit are interested in fairness.
See Beeck v. Aquaslide ‘N’ Dive Corp. for another civil procedure case involving products liability.