Manning v. Manning
2015 WL 144990, 2015 U.S. Dist. LEXIS 3139, 304 F.R.D. 227 (2015)
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Rule of Law:
A party is "required" under Fed.R.Civ.P. 19(a) if the court cannot accord complete relief without them or if their absence would prejudice their or existing parties' interests; if such a party cannot be joined without destroying subject-matter jurisdiction, the court must determine, using factors under Rule 19(b), whether the action should proceed or be dismissed.
Facts:
- On February 22, 2013, a decree was entered probating the Last Will and Testament of Edward Richard Manning and appointing his widow, Joan Fritschen Manning, as executrix of his estate.
- On June 24, 2013, a judgment closing Edward Richard Manning's estate was entered, adjudging Joan Fritschen Manning to be his sole heir-at-law and owner of land in Pike County.
- On or about October 4, 2013, Joan Fritschen Manning sold the land in question to Robert and Paige Perry.
- The plaintiffs, Edward Richard Manning's siblings (including L.H. Manning), allege that Edward held the land in an implied (constructive or resulting) trust for himself and his siblings, based on their parents' intent to divide the land equally when conveying it to Edward by Quitclaim Deed.
- The plaintiffs contend the land was mistakenly included in Edward Richard Manning's Last Will and Testament and seek to have the Quitclaim Deed set aside and the land conveyed to them.
- On or about October 21, 2013, Robert and Paige Perry recorded a deed of trust among the land records of Pike County, naming Pike National Bank as the lender and mortgagee.
Procedural Posture:
- On August 13, 2013, the plaintiffs filed a Complaint to Recover Land (Cause Number 2013-0421) in the Chancery Court of Pike County, Mississippi.
- On August 13, 2013, the plaintiffs also filed a Complaint for Injunctive Relief (Cause Number 2013-0081) in the Pike County Chancery Court.
- On December 2, 2013, the plaintiffs voluntarily dismissed both their state court Complaints without prejudice.
- On December 26, 2013, the plaintiffs filed their current Complaint in federal district court, seeking a determination of land ownership, recovery of land, and damages against Joan Fritschen Manning, Robert Perry, and Paige Perry, alleging diversity jurisdiction under 28 U.S.C. § 1332.
- The defendants filed a motion to dismiss for failure to join a required party under Federal Rule of Civil Procedure 12(b)(7).
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Issue:
Does Federal Rule of Civil Procedure 19 require the joinder of a mortgagee bank in an action seeking to determine land ownership and set aside a deed, and if so, must the action be dismissed when the bank's joinder would destroy the court's diversity jurisdiction?
Opinions:
Majority - david bramlette
Yes, Federal Rule of Civil Procedure 19 requires the joinder of Pike National Bank, and the action must be dismissed because the bank's joinder would destroy diversity jurisdiction. The court first determines if Pike National Bank is a 'required party' under Rule 19(a). As a mortgagee, Pike National Bank claims an interest in the subject property. The court cannot accord complete relief among the existing parties in the Bank's absence, and the Bank's absence could impair its ability to protect its interest or expose existing parties to double or inconsistent obligations. The Mississippi Supreme Court has held that proper adjudication of real property disputes requires the presence of all persons owning interests. Thus, Pike National Bank is a required party under Rule 19(a). Second, the court assesses feasibility of joinder. Pike National Bank is a resident citizen of Mississippi, as is plaintiff L.H. Manning. Therefore, joining Pike National Bank would destroy complete diversity of citizenship, divesting the court of subject-matter jurisdiction. Finally, under Rule 19(b), the court considers whether, in equity and good conscience, the action should proceed among the existing parties or be dismissed. The plaintiffs' interest in a federal forum is weak, as an adequate remedy is available in Mississippi state court where they previously filed similar complaints. The defendants have an interest in avoiding multiple litigation and inconsistent relief. Prejudice to Pike National Bank is clear, and it cannot be lessened by shaping relief. The public interest in efficient dispute resolution favors dismissal to avoid multiple litigation. The court finds that Pike National Bank's interest aligns with the defendants and it cannot be made an involuntary plaintiff. Therefore, the action must be dismissed for failure to join a required party.
Analysis:
This case exemplifies the strict application of Fed.R.Civ.P. 19, demonstrating that even when a plaintiff prefers a federal forum, the necessity of joining parties whose absence would preclude complete relief or risk prejudice to existing parties or the absent party often takes precedence. It underscores that if an 'indispensable' party's joinder destroys diversity jurisdiction, and an adequate alternative forum exists (especially where the plaintiff previously pursued state court remedies), dismissal without prejudice is the appropriate outcome. The decision highlights how state law, particularly concerning real property interests, can influence a federal court's Rule 19 analysis, reinforcing the practical considerations behind the rule.
