## Facts

- Mattel, Inc. (Delaware corporation headquartered in California) sued Carter Bryant (Missouri resident and former Mattel designer) in California state court, alleging contract and tort claims tied to Bryant’s creation of the “Bratz” doll concept.
- Bryant removed to federal court on diversity grounds; the case was initially remanded for failure to show the jurisdictional amount, then removed again after discovery and met with another remand motion.
- MGA Entertainment, Inc. (California corporation that manufactured and marketed Bratz dolls) intervened as a defendant under Federal Rule of Civil Procedure 24 to protect its asserted interests in the Bratz intellectual property.
- The district court found complete diversity between Mattel and Bryant and an amount in controversy exceeding $75,000, and ruled that MGA’s intervention did not defeat jurisdiction because MGA was not an indispensable party under Rule 19.
- The district court certified the jurisdictional ruling for interlocutory appeal under 28 U.S.C. § 1292(b).

## Issues

1. Whether a nondiverse intervenor destroys diversity jurisdiction when the intervenor is claimed to be an indispensable party under Federal Rule of Civil Procedure 19.
2. Whether the district court abused its discretion in concluding that MGA was not indispensable, thereby permitting the case to remain in federal court.

## Decision

- The Ninth Circuit affirmed the order denying remand.
- Diversity jurisdiction existed between Mattel and Bryant and was not destroyed by MGA’s intervention.
- The court held that intervention defeats diversity only if the intervenor is indispensable under Rule 19, and the district court did not abuse its discretion in finding MGA not indispensable.

## Legal Principles

- Complete diversity and the amount in controversy requirement govern diversity jurisdiction, but a nondiverse intervenor defeats jurisdiction only if the intervenor is indispensable under Rule 19.
- “Intervention destroys diversity if the intervening party is indispensable.”
- Indispensability determinations under Rule 19 are reviewed for abuse of discretion.
- Rule 19 analysis considers, among other factors, whether complete relief can be afforded among existing parties, whether an absent party’s interests would be impaired, and whether existing parties face a substantial risk of multiple or inconsistent obligations.
- A plaintiff’s ability to obtain complete relief on its claims against the existing defendant supports a finding that a nondiverse intervenor is not indispensable.

## Conclusion

The Ninth Circuit held that MGA’s nondiverse intervention did not defeat diversity jurisdiction because MGA was not indispensable under Rule 19, and it upheld the district court’s refusal to remand the case to state court.


Mattel, Inc. v. Bryant, 446 F.3d 1011 (9th Cir. 2006)