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Z & B Enterprises, Inc. v. Tastee-Freez International, Inc.

United States Court of Appeals for the First Circuit
2006 U.S. Ap. LEXIS 1124 (2006)


Facts

The purchasers (plaintiffs) of a franchise in Puerto Rico sued the franchisor, Tastee-Freez (defendant) in the United States District Court for the District of Puerto Rico for fraud and deceit during the sale. The purchasers sought to rescind their contracts with the sellers, alleging that Tastee-Freez was liable for the sellers’ actions and that Tastee-Freez did not support the franchise nor make required disclosures. The purchasers separately sued the sellers in a Puerto Rican court. Tastee-Freez moved to dismiss the case under Federal Rule of Civil Procedure (FRCP) 19, alleging that the sellers were necessary and indispensable parties because the purchasers could not get complete relief in their absence, which exposed Tastee-Freeze to multiple and inconsistent liability, and the sellers' joinder would destroy subject-matter jurisdiction. The district court granted the motion to dismiss. The sellers appealed.

Rule of Law

Issue

Holding and Reasoning (Torruella, J.)

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