Calcote v. Texas Pac. Coal & Oil Co.

The principles governing the determination of whether parties are indispensable or merely necessary are apparently simple and constant. In applying them, however, in individual cases, the decisions have made, and are making, it increasingly difficult for courts to say categorically and with the voice of authority who are and who are not indispensable parties.1 It might be supposed then that in the general confusion I should regard myself as without sure guide and compass and as compelled, therefore, to concur in, rather than dissent from, the considered judgment of my associates, that…