Sequeira v. United States Department of Homeland Security, 4:22-cv-07996

Plaintiffs alleged that certain money transfer companies shared their private financial records with law enforcement, in violation of the Right to Financial Privacy Act (RFPA) and California’s Unfair Competition Law (UCL).
The records allegedly were collected and shared through the Transaction Record Analysis Center (TRAC), which was established by Arizona law enforcement entities and involved in large-scale data-gathering focused on border-region money transfers.
Plaintiffs asserted the transfers targeted immigrants and communities of color, and that the companies knew multiple federal agencies could access the records.
Plaintiffs sought damages and injunctive relief against money transfer companies and various federal agencies.
Money Transfer Defendants moved to dismiss, arguing under Rule 12(b)(6) (failure to state a claim) and Rule 12(b)(7) (failure to join Arizona and its Attorney General as necessary parties under Rule 19).
The Arizona Attorney General formally claimed an interest in the litigation due to its subpoena authority, making Arizona a required (but unjoinable) party because of sovereign immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is Arizona a required party under Rule 19?	Arizona had not previously claimed an interest and only policy interests are at stake, not a legally protected interest.	Arizona has a direct, legally protected interest in enforcing its subpoenas for financial records.	Arizona is a required party because it claimed a directly relevant interest.
Can Arizona feasibly be joined?	Did not contest infeasibility due to sovereign immunity.	Joinder is infeasible because Arizona is protected by Eleventh Amendment sovereign immunity.	Arizona cannot be feasibly joined.
Should the case be dismissed if a required party cannot be joined?	The court could fashion relief (e.g., damages, limited injunctive relief) without prejudicing Arizona’s interests or causing inconsistent obligations.	No conceivable relief would avoid prejudicing Arizona’s legally protected interests or avoid inconsistent obligations for defendants.	Dismissal is required; case cannot proceed in equity and good conscience without Arizona.
Can amendment cure the defect?	Requested leave to amend to add parties or claims.	Amendment would not cure the fatal Rule 19 defect due to sovereign immunity.	Amendment denied; dismissal with prejudice.

United States v. Bowen, 172 F.3d 682 (9th Cir. 1999) (Rule 19 necessary party must affirmatively claim a legally protected interest)
E.E.O.C. v. Peabody Western Coal Co., 610 F.3d 1070 (9th Cir. 2010) (public entity is necessary party if validity of its practices is challenged)
Dawavendewa v. Salt River Project Agr. Imp. & Power Dist., 276 F.3d 1150 (9th Cir. 2002) (dismissal proper when indispensable party can't be joined)
Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (1984) (Eleventh Amendment prohibits joining states as defendants in federal court)