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.
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.
On the contrary, given advantages of economy and convenience and no unfairness to litigants, Gibbs contemplates adjudication of these claims.View Full Point of Law