Brief Fact Summary. Delores Kedra, her eight children and a son-in-law (Plaintiffs), brought an action against the City of Philadelphia (Defendant), alleging that the Defendant committed a systematic pattern of harassment against their family over a fifteen-month period. Defendant claims improper joinder of parties, because the events did not occur over a span of fifteen months.
Synopsis of Rule of Law. Claims that occur over a lengthy period of time may be reasonably related and thus arise out of same transaction or occurrence.
Facts. Plaintiffs’ complaint alleges that two of the Kedra children and the husband of another were arrested on December 22, 1975, without probable cause, beaten, and interrogated at the police station. Seven days later, police officers conducted an unlawful search of the Plaintiffs’ home, unlawfully detained members of the family and took some members to the station where they were beaten. It is further alleged that police engaged in a systematic pattern of harassment of Plaintiffs. One son was arresting and beaten in June, 1976, and another son was harassed by police in February or March, 1977. Plaintiffs jointly filed suit under civil rights statutes, 42 U.S.C. Section:Section: 1983, 1985, 1986, for deprivation of constitutional rights and sought compensatory and punitive damages. Defendants argued improper joinder of parties, because Plaintiffs’ claims against them did not arise out of the same transaction or occurrence. The claims stemmed from events spanning fifteen months.
Issue. Was the joinder of the Defendants procedurally proper? Was a single trial of all claims against all defendants would prejudice any of the defendants?
Held. Yes, joinder of Defendants was proper. On the second issue, the district court decided that it should be determined after discovery has been completed and the case is ready for trial. The claims against Defendants arise out of the same transaction or occurrence or series of transactions under Rule 20(a) of the Federal Rules of Civil Procedure and therefore joinder of Defendants is proper. Even though the events giving rise to Plaintiffs’ claims occurred over a long period of time, they are all reasonably related. The district court determined that the problem of whether to have a single trial of all claims against Defendants should be dealt with after discovery and when the case is ready to go to trial. Rule 20(b) states that the court may order separate trials to prevent delay or prejudice. Here, both the Plaintiffs and Defendants recognized potential prejudice in the joinder of the parties. The district court held that it was easier to determine the prejudicial effect of joinder after discovery takes place and the case is ready to go to trial. The court stated that it was easier to determine the prejudicial effect of joinder after discovery takes place because at that time the degree of involvement of each of the Defendants will be clearer and prejudice will be easier to assess.
Discussion. Some of the benefits of a single trial are that it is more convenient and less expensive and time-consuming for the parties and the court. Rule 20(a) allows for the joinder of multiple persons if they assert a right to relief that arises out of the same transaction or occurrence and if there is a common question of law or fact. Joinder of parties is more restrictive than joinder of claims. Joinder of parties is divided into permissive joinder (Rule 20) and mandatory joinder (Rule 19). On the other hand, Rule 18(a) allows a party to join as many claims as the party has against the opposing party. In terms of joinder of claims, the Federal Rules allow claims to be joined that are not even related. The theory behind this rule is that it will prevent the parties from bringing multiple lawsuits against one another.