Law School Case Brief
Camacho v. Major League Baseball - 297 F.R.D. 457 (S.D. Cal. 2013)
The failure to join a party under Rule 19 can only lead to dismissal of a suit where the court cannot obtain jurisdiction over the necessary party and that party is determined to be indispensable to the action.
Plaintiffs David Gonzalez Camacho, baseball agent, and Daniel Arrellano Pesqueira commenced this tort action against multiple defendants. This action arises from allegations that Major League Baseball conspired with the Mexican Major Leagues to prevent baseball prospect Pesqueira from playing baseball in the United States. The Boston Red Sox notified Gonzalez that Pesqueira would be returned to Mexico "based upon the direction of Major League Baseball" because Pesqueira "belonged to a Mexican league team, Diablos Rojos,and could not play in the major leagues without the consent of the Mexican league team." Defendants, the Office of the Commissioner of Baseball (d/b/a Major League Baseball), Major League Baseball Enterprises, Inc., and Major League Baseball Properties, Inc. filed a motion to dismiss.
Should the district court dismiss plaintiffs' suit for failure to join a party under Rule 19?
Plaintiffs' primary arguments addressing indispensability are: (1) Defendants fail to meet their burden, in part, because all of the cases cited are distinguishable, and (2) in equity and good conscience, this case should be allowed to proceed regardless of whether the Red Devils and the Mexican League are indispensable. The Court rejected these arguments. Plaintiffs either misread or misunderstand the cited case law, and they also fail to provide any law themselves that provides an avenue for the Court to bypass Rules 12(b)(7) and 19 and all of the related case law as they implore the Court do. Plaintiffs are, for all practical purposes, attempting to set aside a contract. And it is evident from the allegations in the complaint that the Diablos Rojos, as a party to the alleged contracts, and by extension the Mexican League, are parties that will be affected by any determination regarding the validity of the contracts. If Plaintiffs want to record an earned run against the absent pitchers, Plaintiffs need to face them. Thus, under binding precedent, the Diablos Rojos and the Mexican League are indispensable parties to the action. Consequently, all four of the Rule 19(b) factors weigh in favor of dismissal.
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