Great American Alliance Insurance Company v. Doctors Hospital of Augusta, LLC., 1:23-cv-00190

Great American Alliance Insurance Company issued a workers’ compensation insurance policy to U.S. Engine Valve Corporation.
Two employees (Cobb and Toney) were injured at work and treated at Doctors Hospital of Augusta, which billed over $8.7 million for their care.
Great American paid just over $585,000 in accordance with the South Carolina Workers’ Compensation Act and sought declaratory relief that this amount (based on state schedules) should be considered full payment.
Doctors Hospital counterclaimed, seeking a declaration of liability for the entire amount billed (or what is reasonable), and attempted to join the Patients and U.S. Valve as parties, citing contract claims against them as well.
The hospital moved to add the Patients and U.S. Valve under Rules 19 (necessary joinder) and 20 (permissive joinder), arguing their interests would be impacted.
The current decision denies that motion to join additional parties.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is joinder of Patients & Employer necessary under Rule 19?	Not necessary; court can give relief among existing parties; no pending claim against those absent	Necessary, as their potential liability could be affected	Not necessary; relief can be granted without them
Must the court join parties not claiming an interest?	Joinder improper if absent parties haven’t claimed an interest	Interests of absent parties could be impaired in their absence	Joinder not warranted as no interest has been claimed
Should the court allow permissive joinder under Rule 20?	Joinder would create unnecessary delay and burden; declaratory relief is narrow	Claims arise from same events, with overlapping facts/law	Declined; risks unnecessary burden, prejudice, and inefficiency
Can breach of contract claims be brought against non-parties via counterclaim?	Counterclaims may not solely target non-parties	Permissive joinder to cover all possible claims	Breach of contract claims against non-parties not allowed under Rules

Torcise v. Cmty. Bank, 116 F.3d 860 (11th Cir. 1997) (court’s Rule 19 decisions are controlled by pragmatic considerations)
Challenge Homes, Inc. v. Greater Naples Care Ctr., Inc., 669 F.2d 667 (11th Cir. 1982) (assessing the need for party joinder based on whether all legal interests are present)
Swan v. Ray, 293 F.3d 1252 (11th Cir. 2002) (district courts have broad discretion over joinder under Rule 20)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (1966) (Rule 20 designed to promote convenience and avoid multiple lawsuits)