Council of School Officers v. Vaughn

I concur in the majority’s holding that we should not reach the merits, for CSO failed to join an indispensable party, namely, the District of Columbia. Indeed, the District, as the party responsible for paying the salaries of CSO’s members, is the only potential defendant against whom CSO could obtain the relief it seeks. I also join my colleagues in holding that Vaughn and Rumsey are not appropriate parties defendant, that CSO can gain nothing from their presence in the litigation, and that the complaint should forthwith be dismissed against each of them.1

I am, however, unable to agree that…