The Provident Tradesmens Bank & Trust Co. v. Patterson case in 1967 revolved around the issue of compulsory joinder, a legal principle that requires certain parties to be included in a lawsuit for it to proceed fairly and effectively. The bank, acting as an administrator of an estate, filed suit against several defendants seeking recovery for damages from a car accident that resulted in death. However, one potential defendant (the driver) was not joined due to jurisdictional issues - he lived out-of-state and could not be served with process under Pennsylvania law where the suit was filed. The Supreme Court held that this did not prevent the court from proceeding with the case without him because his absence would not prejudice those already party to the action or substantially impair his ability to protect his interest if he were later sued on similar grounds elsewhere. It ruled that while Rule 19 of Federal Rules of Civil Procedure required all materially interested parties be joined if possible ("necessary"), they need only join "indispensable" parties whose interests are so connected with claims at issue they must participate for any judgment rendered to be fair and just.

In the dissenting opinion for Provident Tradesmens Bank & Trust Co. v. Patterson, Justice Harlan argued that the majority's decision to allow a party not originally named in a lawsuit to intervene after the statute of limitations had expired was incorrect and would lead to unnecessary complications in future cases. He believed that allowing such interventions could potentially disrupt settled expectations and create uncertainty about final judgments. Furthermore, he contended that it was unfair for an intervenor who failed to protect their interests initially by joining as an original party or intervening promptly should be allowed another chance at litigation simply because they claim an interest relating to property or transaction which is subject matter of action.