Reported / Citable
Background
Dematic Corp. sued Helen of Troy, L.P., Steel Technology, LLC, and the Fayette County Industrial Development Board of Fayette County, Tennessee. Fayette County had separately moved to dismiss the claims against it under Rules 12(b)(6) and 12(b)(1).
On July 10, 2025, all parties filed a joint stipulation seeking dismissal without prejudice of Fayette County only. They invoked Rule 41.
The Court’s Holding
Chief Judge Sheryl H. Lipman construed the parties’ stipulation as a motion under Rule 21 rather than Rule 41. The court explained that Rule 21 is the proper procedural vehicle for dropping one defendant in a multi-defendant case.
The court dismissed all claims against Fayette County without prejudice. It expressly left Dematic’s claims against Helen of Troy and Steel Technology pending, and denied Fayette County’s pending dismissal motions as moot.
Key Takeaways
- A request to dismiss only one defendant in a multi-defendant action is properly handled under Rule 21.
- Fayette County was dismissed without prejudice.
- The dismissal did not resolve claims against the remaining defendants.
Why It Matters
The order illustrates the procedural distinction between dismissing an action and dropping an individual party. Once Fayette County was removed from the case, its pending jurisdictional and merits dismissal motions no longer required adjudication.