Is Ohio EPA Director 'Indispensable Party' Who Must Be Joined in Suit Challenging Solid Waste District's Rules?

National Solid Wastes Management Association v. Stark-Tuscarawas-Wayne Joint Solid Waste Managment [sic] District, Case no. 2009-0211

5th District Court of Appeals (Stark County)

ISSUE: Did the court of appeals err in ordering dismissal of a lawsuit that challenged the validity of administrative rules adopted by a local solid waste management district on the basis that that plaintiff's complaint failed to join the director of the Ohio Environmental Protection Agency (OEPA), as an "indispensable party" whose participation was necessary to resolve the legal issues in dispute?