Temple v. Synthes Corp.
United States Supreme Court
498 U.S. 5, reh’g denied, 498 U.S. 1092 (1990)
Temple (plaintiff), a Mississippi resident, had a spinal plate and screw device manufactured by Synthes (defendant) implanted during surgery in a Louisiana hospital, and one of the screws later broke off inside his back. Temple sued Synthes in federal district court and separately sued the hospital and surgeon in Louisiana state court. Synthes moved to dismiss the federal suit for failure to join the doctor and hospital as necessary parties under Federal Rule of Civil Procedure 19, and when Temple did not join them within the court-ordered 20 days, the district court dismissed the case; the court of appeals affirmed, and the Supreme Court granted certiorari.
Whether joint tortfeasors must be joined as necessary and indispensable parties in a single lawsuit, such that failing to join them requires dismissal of a federal claim against one of them.