Also known as: FRCP 19 · Fed. R. Civ. P. 19 · Rule 19 · required joinder · joinder of parties
Written by attorneys · grounded in primary & secondary sources — see below
A federal procedural rule that mandates joinder of a nonparty if feasible when the court cannot accord complete relief among existing parties without that person or when the person claims an interest that may be impaired by the litigation.
Blue Production sued East Industries for defective control boards supplied under contract. East moved before answering to dismiss under Rule 12(b)(7) because Ash Industries had fabricated the boards and assumed warranty duties. The court considered whether Ash's absence prevented complete relief between the named parties.
Summit Machines sued Metro Fabrication on a diversity contract claim. Metro joined Apex as a third-party defendant. Summit then asserted direct defect claims against Apex. Apex moved to dismiss those claims because adding a same-state party through Rule 19 joinder would destroy complete diversity.
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River Ocean sued in State A court over land in State B. The court applied its own procedural rules to questions of joinder of parties while using the law selected under the most-significant-relationship test for substantive property issues.
A plaintiff failed to join a required party under Rule 19 after repeated court orders. The defendant moved to dismiss under Rule 41(b). The court dismissed the action without prejudice because the order expressly noted the failure to join a Rule 19 party.
Two defendants were tried together for robbing six poker players in one game. After acquittal on charges involving five victims, the state sought to prosecute the sixth robbery separately. The court held that the prior acquittal barred relitigation of the shared identity issue.
A diversity action was dismissed on statute-of-limitations grounds. The defendant later argued that the dismissal barred a subsequent state-court suit on the same claim. The court examined whether the federal judgment carried claim-preclusive effect under state law.
A nonparty must be joined if feasible when the court cannot accord complete relief among the existing parties in that person's absence. The focus remains strictly on relief between those already before the court.
Supporting sources
Section 1367(b) bars supplemental jurisdiction over claims by plaintiffs against persons joined under Rule 19 when the exercise of jurisdiction would be inconsistent with the complete-diversity requirements of section 1332.
Supporting sources
A dismissal for failure to join a party under Rule 19 does not operate as an adjudication on the merits unless the order states otherwise.
Supporting sources
…the permissible scope of the doctrine in relation to the liberal provisions of the Federal Rules of Civil Procedure for joinder of parties and claims. Kroger commenced as a suit between a citizen of Iowa and a Nebraska corporation. When the Nebraska defendant impleaded an Iowa corporation as a third-party defendant under…