Federal courts have generally discouraged the joinder of a third party solely on the basis of a claim pendent to a federal cause of action. They have, however, been more liberal in allowing joinder in diversity cases. The author reviews the case law and argues that a more liberal attitude toward joinder should be adopted, except in diversity cases where, he believes, liberal joinder erodes the requirement of complete diversity.
William H. Fortune, Pendent Jurisdiction - The Problem of "Pendenting Parties", 34 U. Pitt. L. Rev. 1 (1972).