Provident Tradesman’s Bank and Trust Co. v. Patterson case brief
Posture: District court for plaintiffs against insurance company, Ct of appeals reverses and SCOTUS reverses again.
Facts: A car owned by Dutcher was being driven by Cionci, who had the keys, while Lynch and Harris were passengers. The car collided with Smith, with Lynch and Smith being killed and Harris severely injured. Provident sued Cionci in diversity. Lynch’s action against Cionci settled.
Dutcher had an insurance policy and was sued; the insurance policy provided that someone had to be driving Dutcher’s car with his permission. However, there is evidence that Cionci made a detour from errand he was supposed to run, so insurance policy decided not to honor the policy. Lynch, who was not paid by Cionci, wants insurance company to pay and tries to prove Cionci drove with permission.
District ct let Lynch win. Insurance company appeals. Ct of appeals reverses on grounds that were not raised in court, that Dutcher was an indispensable party in the suit. Dutcher was held incompetent to testify Under Pennsylvania Dead Man rule; appeals ct said that the right of a person whose rights may be affected is a substantive right and that trial may not proceed and since with Dutcher there was no diversity, suit dismissed.
Reasoning: Rule 19(a) says that a party should be joined if feasible and then 19(b) talks about what is feasible. There are four interests;
1) Plaintiff has an interest in having a forum, with a stronger interest if he won in trial level (2) Defendant should avoid multiple litigation or inconsistent relief, but if defendant fails to assert that interest, it’s closed. (3) Outside who wanted to join must be considered. Without that outside its not res judicata; however, if it is appealed, it cannot affect interest of outsider. (4) Public need to be consistent and efficient.
For 3, its not about whether 3rd party benefits but whether he is harmed by judgment. Basically court found that weighing all of the issues results in them deciding that no one was harmed by the judgment and no one’s interest was being hurt. Therefore it should be reversed and judgment for plaintiff sustained. Their main decision was one that ct of appeals should not have reversed because it was pointless on appeals, and reversing at that point is wasting time.
Important question: Given substantive involvement of outsider, is it proper to adjudicate as between the parties?