Helzberg’s Diamond Shops, Inc. v. Valley West Des Moines Shopping Center, Inc.

United States Court of Appeals for the Eighth Circuit

564 F.2d 816 (8th Cir. 1977)

A party is not considered an indispensable party to a cause of action arising out of a contract solely because that party's rights will be affected in an entirely separate contract.

Relevant Facts

Helzberg's Diamond Shops, Inc., a Missouri corporation (the plaintiff), entered into a written contract with the Valley West Des Moines Shopping Center, Inc., an Iowa corporation (the defendant). The contract stated that the defendant was not to allow more than two other full-line jewelry stores to move into the shopping center. Subsequently, the defendant entered into lease agreements with two other jewelry stores and allowed those jewelry stores to be located within the shopping center. After learning the defendant entered a third lease agreement with a full-line jewelry store, Lord's Jewelers (Lord's), the plaintiff filed suit in federal court on the basis of diversity jurisdiction. The plaintiff sought injunctive relief to restrain the defendant from breaching the lease agreement. The defendant moved to dismiss the action for failure to join Lord’s, claiming that Lord’s was an indispensable party to the suit. The district court denied the motion and granted the plaintiff preliminary injunctive relief. The defendant appealed.

Issue

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Holding & Reasoning

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Concurrence

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Dissent

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Last updated:

December 20, 2020

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Procedural History

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Citations

564 F.2d 816 (8th Cir. 1977)