DIRECTV v. Loussaert

Brief Fact Summary.

DIRECTV sued Loussaertand the remainder of the defendants for intercepting and pirating its television signals.

Synopsis of Rule of Law.

The separate acts of several defendants against an individual plaintiff are part of the same transaction or occurrence if the same statute was violated and the plaintiff seeks the same relief from each defendant.

Facts.

DIRECTV found evidence that the defendants purchased devices to intercept and pirate its television signals. DIRECTV sued and sought equivalent relief from each of the defendants.Eversoll sought to sever the case because each defendant acted independently for their own purposes, so the defendants were not a part of the same transaction or occurrence.

Issue.

Whether the separate acts of several defendants against an individual plaintiff are part of the same transaction or occurrence if the same statute was violated and the plaintiff seeks the same relief from each defendant?

Held.

No. Joinder of the defendants was improper under FRCP 20(a). The defendants shared no common purpose and acted individually without knowledge of the other defendant’s actions.

Discussion.

FRCP 20(a) allows the joinder of multiple parties when the claims against them arise out of the same transaction or occurrence and involve common legal questions.