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Plaintiffs sued Defendants for a systemic pattern of depriving them of their rights. Defendants moved to dismiss the lawsuit for violation of Rule 17 and Rule 20(a).
Under Rule 20(a), joinder of parties is proper for claims all reasonably related. Claims arising over a lengthy period of time does not prohibit joinder, and identity of all events is unnecessary.
Dolores Kedra and her adult and minor children (Plaintiffs) sued The City of Philadelphia and numerous officials and officers of the Police Department (Defendants) for engaging in a systemic pattern of harassment, threats, and coercion with the intent of depriving Plaintiffs of their rights. The allegations included a series of arrests, interrogations, and beatings that spanned fifteen months. All Defendants moved to dismiss the case, arguing that Plaintiff Kedra could not bring the claims on behalf of her minor children and that joinder of the Defendants’ was improper under Rule 20(a).
Can Plaintiff Kedra bring the lawsuit for a deprivation of rights on behalf of her minor children? Is it proper to join Defendants under Rule 20(a) for a series of events spanning fifteen months?
Yes, Plaintiff can bring the lawsuit on behalf of her minor children. Yes, joinder of the Defendants under Rule 20(a) was proper.
The Court first rejected Defendants’ argument that Plaintiff could not bring suit on behalf of her minor children. The minor children have sufficient cause for bringing these claims and under Rule 17 representation of minors by a parent is procedurally proper. Next, the Court rejected the Defendants’ argument that there had been an improper joinder of parties under Rule 20(a). The Court stated that the events involving all Defendants were reasonably related, despite spanning a fifteen month period, because the Plaintiffs were alleging a systemic pattern. Finally, the Court determined that whether all Defendants should be tried in one or separate trails could be determined after discovery.