## Facts

- David Gonzalez Camacho, a Mexican citizen engaged in representing Mexican baseball prospects, entered an exclusive agency agreement with the parents of Daniel Arrellano Pesqueira, a minor and promising player residing in Tijuana, Mexico.
- The agreement gave Camacho exclusive representation rights for negotiations with U.S. major and minor league clubs and entitled him to a commission from Pesqueira’s earnings.
- The Boston Red Sox invited Pesqueira to participate in spring training in the United States.
- Major League Baseball-related entities advised the Red Sox that Pesqueira was ineligible because he allegedly “belonged” to the Red Devils, a Mexican League team, and could not play in the United States without that team’s consent.
- MLB and Mexican League entities produced documents purportedly contracting Pesqueira to play only for the Red Devils; plaintiffs disputed the authenticity and validity of those documents and alleged they were forged or otherwise invalid.
- Plaintiffs sued MLB-related entities asserting state-law tort and unfair competition theories (including interference with prospective economic relations and negligence), alleging MLB knowingly enforced invalid contracts to block Pesqueira’s U.S. opportunity and harm plaintiffs’ economic interests.
- Defendants moved to dismiss the first amended complaint under Federal Rule of Civil Procedure 12(b)(7) for failure to join required parties under Rule 19, identifying the Red Devils and the Mexican League as absent contracting parties whose rights would be affected.

## Issues

1. Whether the Red Devils and the Mexican League were required parties under Rule 19(a) because adjudicating plaintiffs’ claims necessarily implicated their contractual rights and risked prejudice or inconsistent obligations in their absence.
2. If required, whether joinder of those entities was feasible (including whether it would defeat subject-matter jurisdiction or raise personal jurisdiction problems).
3. If joinder was not feasible, whether the action should be dismissed under Rule 19(b) because the absent entities were indispensable and the case could not proceed “in equity and good conscience” without them.

## Decision

- The court granted defendants’ motion to dismiss under Rule 12(b)(7).
- The court held the Red Devils and the Mexican League were required parties under Rule 19(a) because the litigation depended on determining the validity and effect of contracts to which those entities were signatories.
- The court found joinder was not feasible, including because adding the Mexican entities would likely defeat diversity jurisdiction and raised serious personal jurisdiction concerns.
- Applying the Rule 19(b) factors, the court concluded the Red Devils and the Mexican League were indispensable.
- The action was dismissed in its entirety.

## Legal Principles

- A party is required under Rule 19(a) when complete relief cannot be accorded among existing parties without it, or when resolution in its absence may impair its ability to protect its interests or expose existing parties to substantial risk of multiple or inconsistent obligations.
- When claims necessarily require determining the validity and enforceability of contracts, the contracting parties generally have a direct interest that can make them required parties.
- If a required party cannot be joined, Rule 19(b) requires a pragmatic, equitable assessment of prejudice, the ability to shape relief to reduce prejudice, the adequacy of a judgment in the party’s absence, and the availability of an adequate alternative forum.
- Dismissal is appropriate under Rule 12(b)(7) when absent required parties are indispensable and joinder is infeasible.

## Conclusion

Because plaintiffs’ theories turned on whether Pesqueira was bound by alleged Mexican League contracts, the court concluded the Mexican contracting entities had interests that would be directly affected; their absence created substantial prejudice and risk of inconsistent obligations, and joinder was not feasible, requiring dismissal under Rules 19 and 12(b)(7).


Camacho v. Major League Baseball, 297 F.R.D. 457 (S.D. Cal. 2013)