Joinder; Whether the district court abused its discretion by failing to join a defendant under FedRCivP 19’s “necessary, indispensable party” stricture; Whether the court was deprived of subject-matter jurisdiction because one federal party could only be sued in the Court of Claims; Whether the party was “necessary” for complete relief under 19(a)(1)(A) or (B); Whether the party was “indispensable”; Rule 19(b); School Dist. of City of Pontiac v Secretary of U.S. Dep’t of Educ.; Glancy v Taubman Ctrs, Inc

The court reversed the district court’s ruling that it lacked subject-matter jurisdiction in this annuity case and remanded for the district court to analyze whether defendant-DHHS was a “necessary and indispensable” party to the case under Rule 19’s “joinder framework.” William Plott’s estate sued to recover his final annuity payment from defendant-Wilac Life Insurance, which was due two months after his death. Wilcac’s annuity contract was with the DHHS. When Wilac denied payment, the estate sued Wilac and the DHHS. The district court dismissed the case under Rule 19, ruling that the DHHS was a “necessary and indispensable party” and that it lacked subject-matter jurisdiction because the DHHS could only be sued in the Court of Claims. The estate argued that the district court should have joined the DHHS under Rule 19. The court held that the district court failed to engage in the proper Rule 19 framework analysis and rejected any “bright-line rule that that all parties to a contract are necessary and indispensable to lawsuits involving the underlying contract.” These determinations must be made on a case-by-case basis, and without the correct analysis, the court was unable to determine whether the district court found that the DHHS “claims an interest in the litigation that will not be protected in [its] absence.” Neither could the court determine whether the Rule 19(b) factors supported the district court’s ruling that the HHS was “indispensable.”