Litigating the triangle

In Northland Ins. Co. v. Berkebile Oil Co., Judge Michael dealt with the case of a insurer seeking a declaration that a third party was not covered by the contract of its insured, which was not joined as a party to the case. The Court surmised: "One can visualize the relationship between the three parties as a right triangle, with the insurance agreement between Northland and Hydrosol forming the upright segment and the indemnity agreement between Hydrosol and Berkebile forming the lateral segment. Northland’s argument is that the sole issue in this case involves the hypotenuse." The Court concluded that the insured was an indispensable party, and granted the motion to dismiss.