6. When does Federal Rule 13(h) authorize joinder of a party? Can the rule be used to assert a crossclaim against a person who is not already a party to the original action? Can a person who already is a party to the action be made an additional party under Federal Rule 13(h)? Should the rule be read liberally as to encourage judicial economy?

In LASA, Alexander’s claim against the architect, Aydelott, originally was pleaded as a Rule 14 claim. The District Court and the Sixth Circuit treated it as if it were a motion to bring in an additional cross-defendant under Rule 13(h); the courts thus viewed Aydelott as a codefendant on the crossclaims against Southern Builders and the others. Is there a problem with conflating party-joinder under680Federal Rule 13(h) with joinder under Federal Rule 14? See 6 Wright, Miller & Kane, Federal Practice and Procedure: Civil 3d § 1434.