Fred Kuchenig v. The California Company

350 F.2d 551
CourtCourt of Appeals for the Fifth Circuit
DecidedOctober 10, 1965
Docket20803
StatusPublished
Cited by14 cases

This text of 350 F.2d 551 (Fred Kuchenig v. The California Company) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fred Kuchenig v. The California Company, 350 F.2d 551 (5th Cir. 1965).

Opinion

WISDOM, Circuit Judge:

In this diversity action conflicting claims of the plaintiff and of the State of Louisiana to oil-rich water bottoms raise the question whether the State (a) in its capacity as the defendant’s lessor and also (b) in its capacity as a sovereign State asserting title to allegedly inalienable beds of navigable waters is an indispensable party defendant.

The land in suit is in Plaquemines Parish, Louisiana. It is covered by the waters of Breton Sound, an arm of the Gulf of Mexico. The plaintiff, Fred Zuchenig, a resident of Missouri, is the adopted son and sole heir of his uncle, Martin Zuchenig. The plaintiff alleges that at one time the property was swamplands; 1 that the State patented the land in 1911 to one Millard C. Baker; and that, after several intermediate transfers, Martin Zuchenig bought the land in 1912. In 1915 Martin Zuchenig lost the land to the State for unpaid taxes. In 1961 Fred Zuchenig redeemed it. 2 Meanwhile, in 1951 the State, through its Mineral Board, executed Mineral Lease 1960, leasing Tract 4778 to the

California Company. This tract encompasses the property lost to the State for unpaid taxes but later redeemed. The Company has drilled four oil wells on Tract 4778 — two completed wells, two dry holes- — all in navigable waters. The State has received royalties on all production from the two completed wells.

In 1961 Fred Zuchenig filed this peti-tory (title) action against California Company. In addition to asking the court to recognize his sole ownership of the property in dispute, the plaintiff demanded that California Company account for all oil and gas taken from the land. California Company, asserting possession under the mineral lease from the State of Louisiana, moved to dismiss on the ground that the State, an indispensable party, had not been joined. The district court gave Zuchenig leave to join the State; when he failed to do so, the court dismissed the action for failure to join an indispensable party. Fed.R.Civ. P. 19. We affirm the dismissal of plaintiff’s demand for a decree of ownership; we reserve judgment as to the accounting.

I.

A threshold problem is whether, in a diversity action, indispensability is a matter governed by state or federal law.

The Federal Rules of Civil Procedure offer no clear solution. In general, the Federal Rules dealing with joinder are not finely drawn. They derive from common law rules leavened by equity. 3 *553 Rules 19 and 20, after a passing nod to the old common law standard, jointness of interest, 4 adopt by indirection the classification laid down by the Supreme Court in Shields v. Barrow, 1855, 17 How. 130, 147, 15 L.Ed. 158. There Justice Curtis described the “three classes of parties to a bill in equity”: formal, 5 necessary, and indispensable. 6 Rule 19, dealing with “necessary joinder”, refers to “persons who are not indispensable, but who ought to be parties if complete relief is to be accorded between those already parties”. 7

Rule 19 gives no content to the term “indispensable”. The .rule is said to be merely declaratory of existing law. 8 It is questionable, however, whether Rule 19 is declaratory of federal law or of state law, or, indeed, of either.

In Hanna v. Plumer, 1965, 380 U.S. 460, 85 S.Ct. 1136, 14 L.Ed.2d 8, decided in April of this year, the Supreme Court discussed the relationship between the Federal Rules, the Rules Enabling Act, 9 and the Constitution. The Court distinguished between the line of cases classifying matters as substantive or procedural for the purpose of adjudicating the validity of various federal rules (Sibbach v. Wilson & Co., 1940, 312 U.S. 1, 61 S.Ct. 422, 85 L.Ed. 479, and progeny) and the line of cases making that classification under the rule in Erie R. Co. v. Tompkins, 1938, 304 U.S. 64, 58 *554 S.Ct. 817, 82 L.Ed. 1188, 10 none of which, said the Court, finally required a determination of the validity of a federal rule. The Court pointed out that Congress has the power to regulate “matters which, though falling within the uncertain area between substance and procedure, are rationally capable of classification as either”, 380 U.S. at 472, 85 S.Ct., at 1144, even where, in absence of an applicable federal rule or federal statute, Erie R. Co. v. Tompkins might require application of state law. A court instructed to apply a federal rule may “refuse to do so only if the Advisory Committee, [the Supreme] Court, and Congress erred in their prima facie judgment that the rule in question transgresses neither the terms of the Enabling Act nor constitutional restrictions”. 380 U.S. at 471, 85 S.Ct. at 1144. The opinion does not undertake to say what, if any, difference there is between the “terms of the Enabling Act” and “constitutional restrictions” — that is, whether the Enabling Act exhausts the power of Congress to regulate practice and pleading in diversity suits. But in any event, the “uncertain area” that the Court mentions includes matters neither so clearly substantive that the Constitution requires that they be governed by state law, 11 nor so clearly procedural that the Court may regulate them simply through its inherent rule-making power. 12

Hanna v. Plumer introduces a helpful double abstraction- — the choice of choice of law. The decision makes clear that the first inquiry for a diversity court seeking the proper source of the law governing indispensability — or any other matter potentially affected by the Federal Rules — is which of the Supreme Court’s two lines of decision is pertinent. Do the Federal Rules “cover” indispensability? That is, does Rule 19, by mentioning indispensability, incorporate by reference the entire body of federal indispensability precedent? The easy answer is, “No”. In the first place, the text of the rule gives not the slightest clue as to the criteria that a federal court should apply in deciding who must, as opposed to who should or merely may, be joined. Second, no federal court faced with a conflict between a state indispensability rule and federal precedent has ever treated the question as one involving the validity of Rule 19. The cases, though many, are widely discrepant *555 as to which law should apply. 13

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Bluebook (online)
350 F.2d 551, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fred-kuchenig-v-the-california-company-ca5-1965.