Law School Case Brief
Eldredge v. Carpenters 46 N. Cal. Ctys. Joint Apprenticeship & Training Comm. - 662 F.2d 534 (9th Cir. 1981)
Fed. R. Civ. P. 19(a) describes two categories of persons who should be joined if feasible. The first category comprises those persons in whose absence complete relief cannot be accorded among those already parties. Fed. R. Civ. P. 19(a)(1). This portion of the rule is concerned only with relief as between the persons already parties, not as between a party and the absent person whose joinder is sought.
Appellee, JATC, joint labor-management committee was established under an agreement that provided for a trust fund contributed to by the parties to the master collective bargaining agreements in the state's construction industry. It administered an apprenticeship and training program for carpenters. Appellants, Eldredge and Mazur, filed suit against appellee, claiming that the apprenticeship program discriminated on the basis of sex in violation of Title VII, 42 U.S.C.S. § 2000e-2. The district court dismissed the action under Fed. R. Civ. P. 19, finding the 4500 employers that participated in the program to be indispensable parties.
Did the district court err in its decision to dismiss the action under Fed. R. Civ. P. 19?
The court reversed the dismissal of appellant individuals' sex discrimination action against appellee joint labor-management committee for failure to join indispensable parties. The court further found that the relief on appellants' claims against appellee as an entity could be afforded by an injunction against appellee alone, thus Fed. R. Civ. P. 19(a)(1) was not applicable. The court found that employers did not have to be joined pursuant to Fed. R. Civ. P. 19(a)(2)(i) as appellee had full authority to structure the apprenticeship program and to select apprentices and that employers ceded any legally protectable interest they had in selecting apprentices to appellee. Thereby, the court remanded for further proceedings.
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