Temple v. Synthes Corp.
498 U.S. 5 (1990)
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Rule of Law:
Under Federal Rule of Civil Procedure 19, potential joint tortfeasors are not necessary parties required to be joined in a single action but are merely permissive parties.
Facts:
- Petitioner Temple, a Mississippi resident, underwent surgery in Louisiana in October 1986.
- During the surgery, Dr. S. Henry LaRocca implanted a 'plate and screw device' in Temple's lower spine at St. Charles General Hospital.
- The device was manufactured by respondent Synthes Corp., a Pennsylvania corporation.
- Following the surgery, the device’s screws broke off inside Temple’s back, causing injury.
Procedural Posture:
- Temple filed a diversity suit against Synthes in the U.S. District Court for the Eastern District of Louisiana.
- Separately, Temple filed an administrative proceeding, and later a lawsuit, against Dr. LaRocca and the hospital in Louisiana state court.
- In the federal action, Synthes filed a motion to dismiss for failure to join necessary parties under FRCP 19.
- The District Court ordered Temple to join the doctor and the hospital as defendants within 20 days.
- When Temple failed to comply, the District Court dismissed his lawsuit with prejudice.
- Temple (appellant) appealed to the U.S. Court of Appeals for the Fifth Circuit, which affirmed the dismissal.
- Temple then petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Under Federal Rule of Civil Procedure 19, are potential joint tortfeasors considered necessary parties who must be joined in one lawsuit?
Opinions:
Majority - Per Curiam
No. Under Federal Rule of Civil Procedure 19, potential joint tortfeasors are merely permissive parties, not necessary parties whose joinder is required. It has long been an established principle that a plaintiff does not need to name all potential joint tortfeasors as defendants in a single lawsuit. The 1966 revision of Rule 19 did not alter this principle, and the Advisory Committee Notes to Rule 19(a) explicitly state that a tortfeasor with joint-and-several liability is a permissive party. Because the doctor and hospital did not meet the threshold requirement of being necessary parties under Rule 19(a), the district court's inquiry should have ended there, and it was an error to proceed to a Rule 19(b) analysis or to dismiss the case for nonjoinder.
Analysis:
This decision reaffirms the traditional principle that the plaintiff is the 'master of the complaint' and can choose which joint tortfeasors to sue. It clarifies the mandatory sequential application of FRCP 19, requiring a court to first find that an absent party is 'necessary' under Rule 19(a) before it can even consider whether that party is 'indispensable' under Rule 19(b). The ruling prevents defendants from using Rule 19 to force the joinder of other potential tortfeasors for reasons of judicial economy alone, thereby protecting a plaintiff's litigation strategy and choice of forum.
