Schutten v. Shell Oil Company
United States Court of Appeals for the Fifth Circuit
421 F.2d 869 (1970)

- Written by Catherine Cotovsky, JD
Facts
Schutten (plaintiff) sued to evict Shell Oil Company (Shell) (defendant) and for an accounting of the removal of natural resources from land in Louisiana. Schutten did not possess but claimed to own the land that Shell leased from the Board of Commissioners of the Orleans Levee District (the Board), who possessed and also claimed ownership of the land. Schutten, a Louisiana resident, brought the matter against Shell in federal district court under diversity jurisdiction. Shell moved to dismiss the matter on the grounds that the Board was an indispensable party who could not be joined to the matter because if the Louisiana-based Board was joined as a party, it would destroy diversity jurisdiction. The district court granted Shell’s motion to dismiss, and Schutten appealed.
Rule of Law
Issue
Holding and Reasoning (Carswell, J.)
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