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State National Insurance Co. Inc. v. Yates

391 F.3d 577 (2004)

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State National Insurance Co. Inc. v. Yates

United States Court of Appeals for the Fifth Circuit
391 F.3d 577 (2004)

Facts

Calvin Yates (defendant), a Mississippi logger, was sued by a landowner for wrongfully cutting down her trees. Yates sought coverage from his liability insurer, State National Insurance Company (State National) (plaintiff), a Texas citizen. State National denied coverage and filed a diversity action in federal court, seeking a declaratory judgment that Yates’s policy did not provide coverage. Yates counterclaimed for breach of contract and bad faith. Yates also asserted claims against Bruce Insurance Agency (Bruce) (defendant), the Mississippi insurance agency that sold him State National’s policy, for professional negligence and negligent misrepresentation. Yates then moved to dismiss, arguing that Bruce was a necessary and indispensable party under Federal Rule of Civil Procedure 19, whose joinder would destroy subject-matter jurisdiction. The district court agreed and dismissed the case. State National appealed.

Rule of Law

Issue

Holding and Reasoning (Higginbotham, J.)

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