Schroeder v. Busenhart

How later courts describe this case

• noting that "comity does not achieve the force of an imperative or obligation”
• “The polestar is whether a reasonable method of notification is employed and reasonable opportunity to be heard is afforded to the person affected”
• trial court’s decision to deny impleader subject to abuse of discretion standard of review
• In deciding whether to permit impleader, a court must consider the following: (1) prejudice to the original plaintiff; (2) complication of issues at trial; (3) likelihood of trial delay; and (4) timeliness of the motion to implead.