Dispensable Joint Venture

In Archer Western Contractors LLC v. McDonnel Group, LLC, the Fifth Circuit applied its precedent in Moss v. Princip to hold that a partnership—and by extension a joint venture—is not necessarily indispensable when each of its partners is a party and “relief can be tailored to reduce prejudice to the absent partnership.” The court also noted that a Rule 17(a) real-party-in-interest argument does not bear on the Rule 19 joinder analysis, because “the fact that an absent person could bring the action as a real party in interest does not of itself make that person a necessary or indispensable party.” No. 25-30321 (Mar. 26, 2026).