civil procedure rule 60

Introduction to Rule 19 in Civil Procedure

  • Rule 19 is critical in the determination of required and indispensable parties in federal court cases.

Analysis of Rule 19(b)

  • Court's Role: Rule 19(b) states that if a party is deemed required under Rule 19(a) but cannot be joined, the court must decide:

    • Equity Considerations: Whether the case should proceed without that party, using the principles of equity and good conscience.

    • Factors for Consideration:

    • Prejudice to Existing Parties:

      • Would a judgment without the absent party prejudice the existing plaintiff?

      • Would such a judgment subject the non-joining party to additional risk or prejudice?

    • Extent of Prejudice:

      • How can prejudice to either side be lessened or avoided? What protective measures can the court implement?

    • Adequate Relief Elsewhere:

      • If the case is dismissed, would the plaintiff have a viable alternative to seek adequate relief?

Practical Implications of Rule 19(b)

  • In practice, courts often find that state courts can handle these issues when federal diversity is destroyed by the need to join an absent party.

  • If a party is identified as required but cannot be joined, the analysis must carefully consider whether proceeding is justifiable based on the above factors.

Required vs. Indispensable Parties

  • If a party is required under Rule 19(a) but not indispensable under 19(b), the court may allow the case to proceed without that party.

  • This involves a judicial discretion grounded in equitable considerations.

Required Parties Under Rule 19(a)

  • Analysis Steps: Before analyzing Rule 19(b), a determination must be made under 19(a) that the absent party is indeed required.

    • If not required, the motion to dismiss should be denied without further analysis.

Case Example: Jani Case Analysis

  • Context: The contract between Underwood and Janney raised questions about joint obligations and liability.

  • Key Concepts:

    • Joint Obligors: Both parties are liable for the entire obligation (e.g., $100 each owes).

    • Several Obligors: Each party owes a specified portion (e.g., $50 each).

    • Joint and Several Liability: Each party can be liable for the entirety owed (e.g., $100), but one can sue for contribution from the other.

Implications of Liability Types

  • The Third Circuit Court of Appeals clarified that Underwood and Shepard Niles were not required parties, allowing for full recovery from one party without the other present.

    • Joint and Several Liability Implications: All parties can be liable for the entire judgment whereas several obligations would allow for separate suits.Hence, the court ruled Underwood did not need Shepard in the case.

Considerations of Res Judicata and Collateral Estoppel

  • In similar case arguments, Shepard Niles argued that interests would be impaired without party joins.

  • The court ruled that the judgment would not preclude future claims involving absent parties, addressing collateral estoppel concerns.

Hypothetical Scenario for Analysis

  • Scenario: Phyllis contracts with Smith (SC) and Deborah (NC) to purchase a painting.

    • Jurisdiction Issue: Phyllis cannot join Deborah due to lack of diversity, which would destroy federal jurisdiction.

    • Strategic Consideration: The potential benefits of filing in either federal or state court are weighed based on jurisdictional complexities.

Legal Writing Exercise

  • Constructing Issue Statements:

    • An issue statement should reflect the legal question and the specific facts at hand, distinguishing between necessary and permissible parties.

    • Example: "Is Deborah a necessary party under Rule 19(a) whose joinder is not feasible, and should Phyllis's action proceed against Smith alone?"

Rules and Standards for Joining Parties

  • **Rule 19(a) Criteria:

    • Rule states that a necessary party must be joined if:

    • A complete relief cannot be granted unless the person is joined, or

    • The person has an interest in the case that may be impaired without their presence.

    • Presence may also prevent a party from being subject to multiple or inconsistent obligations.

Rule 24: Intervention

  • Overview: Rule 24 enables a third party to enter an ongoing case, either as a matter of right (A) or permissively (B).

  • Rule 22: Interpleader

    • Used when multiple parties claim the same right, enabling the court to resolve conflicting claims without favoring any one party.

Motion for Relief Under Rule 60

  • Distinction Between 60(a) and 60(b):

    • 60(a) deals with clerical mistakes while 60(b) deals with relief from final judgments.

  • Timeliness Requirement: A motion under 60(b) must be filed timely, typically within one year following the judgement unless exceptional circumstances exist.

Ethical and Practical Considerations

  • All judicial determinations made under these rules should consider the overarching goals of justice, fairness, and the right to an adequate resolution.

Conclusion

  • The understanding of Rule 19 and associated rules is integral to navigating the complexities of federal civil procedure. This requires careful analysis of jurisdictional issues, party dynamics, and strategic considerations in legal claims. It underpins the necessity of thorough legal education in assessing case precedence and party obligations.