California, United States of America
The following excerpt is from Sparks v. Bank of Am., N.A., B280302 (Cal. App. 2018):
We initially address respondents' contention that the judgment should be affirmed because appellant fails to address the trial court's finding that appellant failed to join his wife, an indispensable party. "A person is an indispensable party to litigation '"if his or her rights must necessarily be affected by the judgment."' [Citation.] Stated differently, 'Where the plaintiff seeks some type of affirmative relief which, if granted, would injure or affect the interest of a third person not joined, that third person is an indispensable party.' [Citation.] These principles have been codified in Code of Civil Procedure section 389." (Washington Mutual Bank v. Blechman (2007) 157 Cal.App.4th 662, 667.)
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