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

Helzberg's Diamond Shops (plaintiff) leased space in Valley West Shopping Center (defendant) under a contract barring the center from allowing more than two other full-line jewelry stores. The center then leased to a third full-line jewelry store, Lord's Jewelers. Helzberg's sued in federal court (diversity) for an injunction restraining the center from allowing the third store. Lord's could not be joined without destroying diversity, so the question was whether Lord's was an indispensable party requiring dismissal.

Whether a party is indispensable to an action merely because its rights or obligations under a separate contract would be affected by the outcome.