Face v. Face

Summary

The Court held that failure to join a necessary party under Rule 19 does not deprive a court of subject matter jurisdiction and that the defendant's Rule 19 challenge was not waived in these circumstances. It further adopted a categorical rule that a revocable trust need not be joined in an equitable distribution proceeding when all of its settlors are named parties, because a judgment against the settlors concerning trust property effectively binds the trust without affecting others' rights. The Court modified and affirmed the Court of Appeals' judgment.