Rule 19.Joinder of Persons Needed for Just Adjudication
Last verified July 2, 2026
Full Text of Rule 19
Advisory Commission Comments
Advisory Commission Comments [2005].
The first sentence of Rule 19.01 is changed to refer to "service of process" rather than "jurisdiction" to make clear that personal rather than subject matter jurisdiction is intended.
Plain-English Summary
Rule 19.01 identifies two situations calling for compulsory joinder of a nonparty who is subject to service of process: when complete relief cannot be given to the existing parties without that person, or when the person claims an interest in the subject of the action and proceeding without that person could, as a practical matter, impair the person’s ability to protect that interest or leave the existing parties exposed to double, multiple, or inconsistent obligations. When those circumstances exist and joinder is feasible, the court must order the person joined — as a defendant, or, if the person should be a plaintiff but refuses to join voluntarily, as a defendant or an involuntary plaintiff in an appropriate case.
Rule 19 is easy to confuse with two other doctrines it is not. It is not the real-party-in-interest requirement of Rule 17, which governs who may bring the claim in the first place rather than who else must be joined to it. And it is not the same as failure to state a claim: when the plaintiff has named the wrong defendant, the correct disposition is dismissal for failure to state a claim, not dismissal for failure to join a supposedly indispensable party.
Rule 19.02 addresses what happens when a person who should be joined under Rule 19.01 cannot be joined — because the court lacks jurisdiction over that person or for some other reason. The court must then decide, in equity and good conscience, whether the action should proceed among the parties already before it, or whether the absent person is so indispensable that the action should be dismissed. Rule 19.03 requires a party who has not joined such a person to state, if known, that person’s name and the reasons for not joining them. Rule 19.04 makes clear that Rule 19 gives way to Rule 23’s separate provisions governing class actions.
Frequently Asked Questions
When must another person be added to a Tennessee lawsuit under Rule 19?
When, under Rule 19.01, that person’s absence would prevent complete relief among the existing parties, or when the person claims an interest that proceeding without them would practically impair, or would expose the existing parties to inconsistent obligations.
What happens if a required person cannot be joined?
Rule 19.02 requires the court to decide, in equity and good conscience, whether the action should proceed without that person or whether the person is so indispensable that the case must be dismissed.
Is Rule 19 the same as suing the wrong defendant?
No. When a plaintiff has named the wrong defendant, the correct outcome is dismissal for failure to state a claim, not dismissal under Rule 19 for failure to join a required party — the two doctrines address different problems.
Advisory Commission Comments [2000].
The original version of 19.01 contained the following language: "This rule shall be construed to allow joint tortfeasors and obligors on obligations that are joint and several to be sued either jointly or severally." The Supreme Court's adoption of comparative fault, where tort liability is several rather than joint, makes the sentence incorrect in part. Samuelson v. McMurtry, 962 S.W.2d 473 (Tenn. 1998), requires that comparative tortfeasors be joined in a single lawsuit.