Wyatt v. County of Stanislaus, 1:21-cv-00455

Plaintiffs, Emmanuel and Makeda Wyatt, allege their seven children were unlawfully removed from their home by Stanislaus County social workers on April 8, 2019, without a warrant or exigent circumstances.
Plaintiffs assert that the removal and subsequent separation violated their Fourteenth Amendment right to familial association.
The juvenile court later returned the children to the parents, but kept the case open with ongoing government oversight.
Plaintiffs seek damages for emotional distress and associated harms, claiming they did not consent to the removal, and no emergency existed.
Defendants moved for judgment on the pleadings, arguing plaintiffs’ children are necessary parties who must be joined under Rule 19.
The court considered whether Rule 19 requires joinder of the children for the action to proceed.

Issue	Plaintiff’s Argument	Defendant’s Argument	Held
Are the absent children necessary parties under Rule 19?	No claims are being brought for them; parents' interests adequately represent children.	Children have an interest that may be impaired, and privity/collateral estoppel may apply.	No, children’s interests are adequately represented by parents.
Will children’s absence impair their ability to protect their interest?	Plaintiffs’ incentive aligns with any shared interest; adequate representation.	Parents may not adequately represent children's interests due to possible conflicts.	No impairment; shared interest means adequate representation.
Could defendants face inconsistent obligations if children aren’t joined?	No, only adjudicative inconsistency possible, not conflicting obligations.	Defendants risk inconsistent obligations or multiple lawsuits.	No risk; inconsistent judgments alone do not require joinder.
Should the motion for judgment on pleadings be granted for non-joinder?	Joinder not required because children are not necessary parties.	Motion should be granted if children not joined.	Motion denied; children not necessary, case can proceed.

Aguilar v. Los Angeles County, 751 F.2d 1089 (9th Cir. 1985) (discusses interest/privity and collateral estoppel risk to absent parties)
Makah Indian Tribe v. Verity, 910 F.2d 555 (9th Cir. 1990) (explains Rule 19 analysis: necessary and indispensable parties)
Washington v. Daley, 173 F.3d 1158 (9th Cir. 1999) (absent parties’ interests can be protected by adequate representation)
Rogers v. County of San Joaquin, 487 F.3d 1288 (9th Cir. 2007) (familial rights under the Fourteenth Amendment and removal standards)
Cachil Dehe Band of Wintun Indians v. California, 547 F.3d 962 (9th Cir. 2008) (distinguishes inconsistent obligations from inconsistent adjudications)