Field v. Volkswagenwerk AG

I agree with the majority that Ivana’s presence as a plaintiff destroyed the complete diversity necessary for the district court’s jurisdiction. I also agree that the citizenship of Arthur’s estate is that of the administratrix rather than of the deceased. However, I am constrained to disagree with the majority’s disposition of two issues: the holding that Ivana in her individual capacity is not an indispensable party and the holding that the complaint may not be amended to substitute Lucille as the administratrix of Arthur’s estate.

I

On the first issue the majority correctly holds that…