Helzberg's Diamond Shops v. Valley West Des Moines Shopping Center

564 F.2d 816 (8th Cir. 1977)

 

RULE:

The determination of whether or not a person is an indispensable party is one which must be made on a case-by-case basis and is dependent upon the facts and circumstances of each case. 

FACTS:

The lessee, a tenant at a shopping mall, had a provision in its lease allowing it to be the only full line jewelry store at the mall. After the lessor entered into a subsequent lease with a full line jewelry store, the lessee brought an action to enforce the lease provision. The trial court granted a preliminary injunction requiring the lessor to abide by the lease provision, after denying the lessor's motion to dismiss for failure to join the affected tenant as a necessary party.

ISSUE:

Should the additional tenant serve as a necessary party to the action in order to afford complete relief?

ANSWER:

No.

CONCLUSION:

The determination of whether or not a person is an indispensable party is one which must be made on a case-by-case basis and is dependent upon the facts and circumstances of each case.  An analysis of the facts and circumstances of the case before us lead us to conclude that Lord's was not an indispensable party and that, therefore, the District Court did not err in denying Valley West's motion to dismiss. Even if, as a result of the District Court's granting of the preliminary injunction, Valley West should attempt to terminate Lord's leasehold interest in space 261 in the Valley West Mall, Lord's will retain all of its rights under its Lease Agreement with Valley West. None of its rights or obligations will have been adjudicated as a result of the present proceedings, proceedings to which it is not a party. Therefore, we conclude that Lord's will not be prejudiced in a way contemplated by Rule 19(b) as a result of this action.

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