Provident Tradesmens Bank & Trust Co. v. Patterson
Case Date: 07/22/1968
Court: United States Court of Appeals
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Provident Tradesmens Bank & Trust Co. v. Patterson, 390 U.S. 102 (1968), is a United States Supreme Court decision which clarified the meaning and application of Rule 19 of the Federal Rules of Civil Procedure. In a unanimous decision, the Court reversed the judgment of the United States Court of Appeals for the Third Circuit and held that an automobile owner's interest in a suit against his insurer did not make him an "indispensable party" to that suit under Rule 19. The Court also made clear that Supreme Court precedent predating the enactment of the Federal Rules of Civil Procedure did not create any substantive right in non-parties to be joined in case, as the Court of Appeals had apparently thought.
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