“A `necessary party' is one who must be joined in the action for a just adjudication." (See In re Paternity of C.M.R (2007) 871 N.E.2d 346, 349.)
“All persons may join in one [1] action as plaintiffs if they assert any right to relief jointly, severally, or in the alternative in respect of or arising out of the same transaction, occurrence, or series of transactions or occurrences and if any question of law or fact common to all these persons will arise in the action.” (See McCoy v. Like (1987) 511 N.E.2d 501, 503.)
“The purpose of T.R. 20(A) is to promote trial convenience, expedite claims, and avoid multiple lawsuits.” (See id.) “To accomplish these ends, Indiana courts give T.R. 20(A) the broadest possible reading, especially in light of T.R. 20(B) and T.R. 42(B), which allow for separate trials after all parties have been joined." (See Russell v. Bowman (2001) 744 N.E.2d 467, 471.)
"Necessary parties to an action are those whose interests in the subject matter are separable and would not be directly affected by the judgment if they were not before the court, but whose joinder would be necessary for a complete adjudication of the controversy.” (See Lucas v. Estate of Stavos (1993) 609 N.E.2d 1114, 1118.)
“An adjudication of an action may be made even if all necessary parties are not joined therein, but when timely objection is made to the nonjoinder of a necessary party the court shall require his joinder if he is subject to its jurisdiction." (See id.)
“To join defendants under T.R. 20(A), three requisites must be met.” (See Russell v. Bowman (2001) 744 N.E.2d 467, 472.)
“First, a right of relief must be asserted against the defendants jointly, severally, or in the alternative.” (See Russell v. Bowman (2001) 744 N.E.2d 467, 472.)
“The second and most important requirement is that the claims arose out of the same transaction, occurrence, or series of transactions or occurrences.” (See id.)
“Indiana courts have applied the logical relationship test in determining whether the causes of action arose out of the same transaction or occurrence.” (See id.)
“For purposes of that rule, all logically related events entitling a person to institute a legal action against another generally are regarded as comprising a transaction or occurrence." (See id.)
“Moreover, ‘[t]ransaction’ is a word of flexible meaning. It may comprehend a series of many occurrences, depending not so much upon their connection as upon their logical relationship.” (See id.)
“The third and final requirement for T.R. 20(A) joinder is that there are common questions of law or fact. Rule 20(A) does not require that every question of law or fact in the action be common among the parties; rather, the rule permits party joinder whenever there will be at least one common question of law or fact.” (See id.)
“Absent any statutory provision for consolidated trials of separately-charged defendants, it is within the trial court's discretion to determine whether defendants' trials should be joined.” (See Peck v. State (1990) 563 N.E.2d 554, 557.)
“To show an abuse of discretion, an appellant must show that in light of what occurred at trial, the denial of a separate trial subjected him to actual prejudice.” (See id.)
It is well settled that “a cause of action arises from the same transaction or occurrence when a logical relationship between the occurrences gives rise to each of the claims.” (See Hayes v. Harris (1985) 479 N.E.2d 1359, 1360.)
It is also well settled that “when a complete determination of the controversy cannot be had without the presence of other parties, the court must cause them to be joined as proper parties.” (See State ex Rel. Kleffman v. Bartholomew Circuit Ct. (1964) 245 Ind. 539, 544.)
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