Haas v. Jefferson National Bank
United States Court of Appeals for the Fifth Circuit
442 F.2d 394 (5th Cir. 1971)
Haas (plaintiff) and Glueck, both Ohio residents, agreed that Haas would purchase Jefferson National Bank (the Bank) (defendant) stock issued in Glueck's name; the Bank allegedly knew of Haas's interest. Glueck later pledged the stock, including Haas's shares, as collateral for a loan at another bank. Haas sued the Bank for conversion in federal court based on diversity jurisdiction (Glueck could not be joined without destroying diversity, since he was also from Ohio). The district court ordered Haas to join Glueck and then dismissed the case for lack of jurisdiction when he could not.
Whether a plaintiff must join an absent party when that party's absence would prejudice the parties before the court or leave the judgment inadequate and incomplete.