Cruz v. Bristol Myers Squibb Co. P.R., Inc.

264 F.R.D. 22, 2010 U.S. Dist. LEXIS 10600, 2010 WL 322694
CourtDistrict Court, D. Puerto Rico
DecidedJanuary 28, 2010
DocketCivil No. 08-1424 (FAB)
StatusPublished
Cited by3 cases

This text of 264 F.R.D. 22 (Cruz v. Bristol Myers Squibb Co. P.R., Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cruz v. Bristol Myers Squibb Co. P.R., Inc., 264 F.R.D. 22, 2010 U.S. Dist. LEXIS 10600, 2010 WL 322694 (prd 2010).

Opinion

MEMORANDUM AND ORDER

BESOSA, District Judge.

On August 29, 2008, this Court issued a Memorandum and Order ordering plaintiffs to show cause “why the court should not dismiss all co-plaintiffs except Cesar I. Cruz his wife and their conjugal partnership (the first named plaintiffs) and order the remaining plaintiffs each to file an individual complaint asserting his individual claims.” (Docket No. 23 at 2) The Court explained in its Memorandum and Order that “none of the plaintiffs [appeared to] assert[s] a right to relief jointly or severally” and, moreover, “it is clear from the complaint that each plaintiff has a different story and will present different evidence.” Id.

On September 17, 2008, the plaintiffs1 2filed a Motion in Compliance of Order (Docket No. [23]*2326) supporting the continued joinder of their claims. On September 26, 2008, the defendants filed their opposition brief (Docket No. 31), contending that the plaintiffs’ claims require separate actions. For the following reasons, the Court finds that plaintiffs have failed to show that their claims should be joined in a single action.

DISCUSSION

Rule 20(a) of the Federal Rules of Civil Procedure states that numerous individuals may join together in a single 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.

Fed.R.Civ.P. 20(a); See also, Coughlin v. Rogers, 130 F.3d 1348, 1350 (9th Cir.1997). “In such a case, the court can generally dismiss all but the first named plaintiff without prejudice to the institution of new, separate lawsuits by the dropped plaintiffs against some or all of the present defendants based on the claim or claims attempted to be set forth in the present complaint.” Id. (internal citation and quotation omitted).

In their Complaint and More Definite Statement of the Complaint (“More Definite Statement”)2, plaintiffs appear to allege that the defendants violated the following laws: the Americans with Disabilities Act (“ADA”); the Age Discrimination in Employment Act (“ADEA”); the Worker Adjustment and Worker Benefit Protection Act; the Consolidated Omnibus Budget Reconciliation Act (“COBRA”); and various local laws. (See Docket No. 1 at 5) Plaintiffs appear3 to also raise a claim under the Employee Retirement Income Security Act (“ERISA”) and a claim alleging breach of contract. (See Id. at 5 and 6).

The plaintiffs’ argument in support of continued joinder addresses only the first prong of Rule 20(a). Without referring to any statutory authority or case law whatsoever, and without citation to the iwo-pronged standard for joinder pursuant to Rule 20(a), the plaintiffs’ rationale for joinder appears to rely on the possibility that their respective harms all arose from a shared “transaction or occurrence” — a termination program. The plaintiffs argue that they filed their claims jointly “because their cause of action arises out of the same transaction or occurrence ...” (Docket No. 26 at 2). Plaintiffs identify their shared transaction or occurrence as “an involuntary termination program that, because of its intent, disparate impact and/or the way it was conceived and executed, violates the Age Discrimination in Employment Act (ADEA) and the Older Worker Benefit Protection Act (OWBPA), as well as other Commonwealth of Puerto Rico and Federal Laws.” Id. The plaintiffs explain that they were all “part of defendant’s one and only termination program,” which contained identical waiver language for the plaintiffs to sign. Id.

[24]*24The plaintiffs thus argue that if the Court found that the same termination program resulted in the dismissal of all three plaintiffs then, regardless of the particular circumstances of each plaintiff, the Court should allow the continued joinder of their claims. The plaintiffs contend “it is clear that the issues to be presented to the Court will hinge on the termination program ... with plaintiffs’ particular circumstances being secondary to the Court’s evaluation of the terms of the program and how defendants executed it and to its evaluation of the language of the waiver.” (Docket No. 26 at 2)

The plaintiffs misunderstand the entire joinder issue, boiling it down to whether all of the plaintiffs were dismissed from their jobs pursuant to the defendants’ termination program. Even if the plaintiffs were dismissed by the exact same termination program, questions critical to the Rule 20(a) joinder analysis remain, such as whether plaintiffs’ claims will require the same questions of law and draw upon the same facts. By focusing all of their attention on the alleged termination program the plaintiffs have failed to demonstrate sufficient questions of law or fact common to all plaintiffs to justify joinder in this action.

The Court agrees with the defendants, who argue that the plaintiffs’ Complaint and More Definite Statement “contain different claims for each of the three plaintiffs which will require separate discovery, and which would more appropriately and efficiently be handled in separate cases.” (Docket No. 31 at 2). As defendants carefully and persuasively explain, the “myriad of claims” alleged by plaintiffs are not all applicable to each plaintiff and, “although plaintiffs share a few facts in common, it is clear that their claims arise from different factual backgrounds and involve distinct questions of law and fact.” (Docket No. 31 at 1 and 3, respectively.)4

The differences among the plaintiffs’ claims, even those arising pursuant to the same federal or state laws, are significant and will require distinct legal analyses. The circumstances leading to these significant differences include: only plaintiffs Cruz and Diaz allege breach of contract claims; the COBRA claims alleging that the plaintiffs were not provided with proper notice will require individualized inquiries regarding each plaintiffs notification (Id. at 4;); plaintiffs Diaz and Cruz were terminated on August 31, 2007 while plaintiff Lasanta was terminated nearly a year earlier, in October of 2006; only plaintiffs Cruz and Lasanta assert disability discrimination claims; the disability claims arise from different circumstances 5 which “although both for disability discrimination, involve different time-frames, different alleged disabilities and adverse actions, with potentially different decisions-makers” (Id. at 3).

The plaintiffs argue that “fragmenting” the plaintiffs’ case “tip[s] the scale in favor of defendants,” and insist that a ruling in favor of severance “would look as if the Court is just protecting its resources and time, which we do not doubt is its only interest.” (Docket No. 26 at 4.) Plaintiffs’ argument makes no sense; just as they misunderstood the joinder issue, the plaintiffs likewise misunderstand the effect of severance on judicial time and resources.

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Related

Gonzalez-Camacho v. Banco Popular De P.R.
318 F. Supp. 3d 461 (U.S. District Court, 2018)
Cruz v. Bristol-Myers Squibb Co., PR, Inc.
699 F.3d 563 (First Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
264 F.R.D. 22, 2010 U.S. Dist. LEXIS 10600, 2010 WL 322694, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cruz-v-bristol-myers-squibb-co-pr-inc-prd-2010.