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Peters v. Singh

United States District Court, M.D. Louisiana

November 6, 2017

EARL PETERS, ET AL
v.
RAMAN SINGH, ET AL

          RULING

          SHELLY D. DICK UNITED STATES DISTRICT COURT.

         Before the Court is a Motion to Sever Plaintiffs' Claims[1]filed by Defendants, State of Louisiana, Louisiana Dept. of Public Safety and Corrections, John Bel Edwards, James LeBlanc, Darryl Vannoy, Raman Singh, and Stephanie Lamartinere ("Defendants"). Plaintiffs, Earl Peters, Iddo Blackwell, Kevin Mathieu, Lavelle Meyers, Dan Riley, Russell Ware, William Dickerson, Ronald Ailsworth, Jimmy Turner, and Herman Bella ("Plaintiffs") have filed an Opposition[2] to this Motion. For the following reasons, Defendants' Motion to Sever Plaintiffs' Claims shall be DENIED.

         I. BRIEF BACKGROUND PROCEDURAL HISTORY

         Plaintiffs are inmates incarcerated at Louisiana State Penitentiary ("Angola").[3] In their Complaint, each Plaintiff alleges the Defendants violated their rights under the Eighth Amendment to the United States Constitution ("Eighth Amendment"), the Americans with Disabilities Act of 1990, 42 USCA § 12101 et seq ("ADA"), and the Rehabilitation Act, 29 USCA § 701 et seq ("RA"). Specifically, Plaintiffs allege that the Defendants implemented policies of denying and/or delaying doctor-prescribed surgeries in deliberate indifference to their serious medical needs in violation of the Eighth Amendment.''[4] The claims of Plaintiffs Mathieu, Blackwell, Riley, Dickerson, and Turner arise out of complaints concerning cataracts. The claims of Plaintiffs Ailsworth, Peters, Meyers, Bella, and Ware, arise out of complaints concerning hernias. Plaintiffs further allege they are qualified persons with disabilities as defined by the ADA, and the disputed policies are facial violations of the ADA.[5]

         In the current Motion, Defendants claim that Plaintiffs fail to meet the requirements for permissive joinder of parties under Federal Rule of Civil Procedure 20.[6] As a result, Defendants move this Court to sever the claims of each Plaintiff into ten (10) separate actions under Rule 21 or, in the alternative, conduct separate trials for each Plaintiff as permitted by Rule 42(b).

         Defendants make four arguments in favor of severance: (1) each Plaintiff has a unique medical history that does not constitute the same transaction or occurrence; (2) the lack of any common facts outweighs any common issues of law; (3) judicial economy would not be facilitated if the cases were tried jointly; and (4) severance will eliminate prejudice. Defendants alternatively argue for separate trials of each Plaintiff in order to avoid the risk of jury confusion and prejudice.

         Plaintiffs, in turn, aver they have met the requirements of Rule 20 and their claims do arise out of the same series of occurrences. Additionally, Plaintiffs argue that severance of the case into ten separate trials would not promote judicial economy given the overlap in witnesses and evidence in each case.

         II LAW AND ANALYSIS

         A. Standard for Motions to Sever

         Under Rule 21 of the Federal Rules of Civil Procedure, a district court has broad discretion to sever improperly joined parties.[7] Since Rule 21 does not provide any standards by which district courts can determine if parties are misjoined, courts have looked to Rule 20 for guidance.[8] Rule 20(a)(1) provides that: Persons may join in one action as plaintiffs if:

(A) they assert any right to relief jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences; and
(B) any question of law or fact common to all plaintiffs will arise in the action.[9]

         Courts have described Rule 20 as creating a two-prong test, allowing joinder of plaintiffs when: (1) their claims arise out of the same transaction, occurrence, or series of transactions or occurrences and, (2) there is at least one common question of law or fact linking all claims.[10] "Under the Rules, the impulse is towards entertaining the broadest possible scope of action consistent with fairness to the parties; joinder of claims, parties and remedies is strongly encouraged."[11]

         When applying the two-prong test, the Court considers whether there is a logical relationship between the claims and whether there is any overlapping proof or legal question.[12] The Court must also consider whether settlement or judicial economy would be promoted, whether prejudice would be averted by severance, and whether different witnesses and documentary proof are required for separate claims.[13] However, even if the two-prong test is satisfied, the Court has the discretion to refuse joinder in the interest of avoiding prejudice and delay, ensuring judicial economy, or safeguarding principles of fundamental fairness.[14]

         B. Common Question of Fact

         Defendants offer a short summary of each individual Plaintiffs medical history in order to show the alleged unique circumstances of each individual Plaintiffs claim.[15]Specifically, Defendants assert that the "severity of cataracts and/or hernia is at issue [for each plaintiff], " therefore, the "collective allegations do not arise out of the same transaction or occurrence."[16] Next, Defendants argue that, although each Plaintiff generally claims violations of the Eighth Amendment and the ADA, the proof and evidence associated with each individual Plaintiffs claim will be different. In similar fashion, Defendants make the same argument in reference to the Plaintiffs' ADA claims: "[n]either cataracts [n]or a hernia is considered a 'disability' under the ...


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