Temple v. Synthes

498 U.S. 5 (1990)


An implanted plate and screw in Temple's (P) back malfunctioned. P underwent surgery wherein the plate and screw were inserted into P’s spine. The screws broke off inside P’s spine. P sued Synthes (D), the manufacturer of the plate and screw, for products liability in federal court. P then sued the doctor and the hospital for negligence and malpractice in state court. D did not use Rule 14(a) to bring a third-party complaint against the doctor and hospital. Instead, D filed a motion to dismiss the federal lawsuit under Fed. R. Civ. P. 19 because P failed to join all the necessary parties. The court gave P twenty days to join the necessary parties in the interests of judicial economy. P did not join the doctor, and the hospital and the court dismissed the suit with prejudice. The court of appeals affirmed that decision: Fed. R. Civ. P 19 allows mandatory joinder of necessary parties in the interest of efficiency. It was stated that D might claim that the doctor and the hospital were negligent and the device was not defective, and on the other hand, the doctor and the hospital would claim that they were not negligent and that the device was defective. P appealed; joint tortfeasors are not indispensable parties under Rule 19(b).