Temple v. Synthes Corp.

Facts

Temple, who lived in Mississippi, had spinal surgery in October 1986. The surgeon implanted a plate and screw device in his lower spine. Synthes, a Pennsylvania corporation, made the device. Dr. LaRocca did the surgery at St. Charles General Hospital in New Orleans, Louisiana. Afterward, the device's screws broke off inside Temple's back. Temple sued Synthes in the federal district court for the Eastern District of Louisiana, relying on diversity jurisdiction. He alleged defective design and manufacture. At the same time, he started a state administrative proceeding against the doctor and the hospital for malpractice and negligence. When it ended, he sued them in Louisiana state court. Synthes did not try to bring the doctor and the hospital into the federal case by a third-party complaint under Federal Rule of Civil Procedure 14(a). Instead, it moved to dismiss for failure to join necessary parties under Rule 19. Synthes did not deny that it, the doctor and the hospital were potential joint tortfeasors, meaning wrongdoers who may each be liable for the same harm.

Issues

1. Are potential joint tortfeasors necessary parties under Federal Rule of Civil Procedure 19, so that a federal court may order the plaintiff to join them as defendants?
2. May a federal court dismiss a plaintiff's suit with prejudice for refusing to join joint tortfeasors as defendants when they are only permissive parties?

Holding

Synthes, the doctor and the hospital were potential joint tortfeasors, so the doctor and the hospital were merely permissive parties under Rule 19(a). The District Court abused its discretion by ordering them joined and dismissing Temple's suit when he failed to comply. The Court of Appeals erred in affirming.