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Supreme Court of the United States - 498 U.S. 5
Tags: Civil Procedure, Joinder
tl;dr:
Joint tortfeasors are permissively joined parties, and do not meet the threshold requirements for FRCP 19(a) compulsory joinder.Video Summary
Case Summary
In the 1990 case of Temple v. Synthes Corp., the US Supreme Court addressed the issue of joining parties in a lawsuit under Rule 19 of the Federal Rules of Civil Procedure. Temple, a Mississippi resident, sued Synthes Corp. in federal court after a medical device manufactured by the company malfunctioned during surgery, causing him injury. He also sued the doctor and the hospital involved in the surgery in state court.
Synthes Corp. argued that the doctor and hospital should be included as defendants in the federal suit, citing Rule 19. The district court agreed and told Temple to add them or face dismissal; when he didn't, the case was dismissed. The appeals court confirmed this decision.
However, the Supreme Court reversed the dismissal, deciding that Temple was not required to include the doctor and hospital under Rule 19. They applied a test for necessity and feasibility and determined that Temple's case did not meet the necessary conditions for including additional parties. The Court emphasized that joint wrongdoers were not required parties under Rule 19, and including them was not necessary to avoid multiple lawsuits or promote judicial efficiency.
This case is important because it clarified the principles of joining parties in a lawsuit, showing how the Court balanced justice, convenience, sovereignty, and respect while assessing federal judicial power. It continues to be cited as an authority on this issue today.
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This case involves a challenge by postal employee unions against the United States Postal Service's suspension of the Private Express Statutes (PES) for private courier services' "international remailing" practice. The Supreme Court ruled that postal employees are not within the "zone of interests" and cannot challenge the suspension. The Court found that the Unions had met the injury-in-fact test, but the Court of Appeals erred in conflating the zone-of-interests test with injury in fact. The PES were enacted to protect the Government's capital investment in post roads and ensure national integration and equal postal service, not to secure employment for postal workers. The Unions' claim that the Postal Service did not comply with the mandate of 39 U.S.C. § 601(b) that the PES be suspended only if the public interest requires is not supported by the language of the statutes and legislative history. The zone-of-interests test should be applied in the light of other relevant provisions, and competitors of regulated entities have standing to challenge regulations.
The court cannot address the hypothetical question of whether Postal Service employees have standing to challenge a regulation that may limit their job opportunities through judicial review because the Postal Reorganization Act's 39 U.S.C. § 410(a) clearly states that the Administrative Procedure Act's judicial review provisions do not apply to the Postal Service's exercise of powers. The case should be dismissed based solely on 39 U.S.C. § 410(a) using the doctrine of judicial restraint. The objection to judicial review may be noticed on the Court's own motion, and it is not necessary to decide whether it can be waived by the Postal Service.
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