Day v. Knox County Sheriff Office

CourtDistrict Court, E.D. Tennessee
DecidedFebruary 21, 2023
Docket3:23-cv-00063
StatusUnknown

This text of Day v. Knox County Sheriff Office (Day v. Knox County Sheriff Office) is published on Counsel Stack Legal Research, covering District Court, E.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Day v. Knox County Sheriff Office, (E.D. Tenn. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT KNOXVILLE

STEVEN DAY, et al., ) ) Plaintiffs, ) ) No.: 3:23-CV-63-DCLC-JEM v. ) ) KNOX COUNTY SHERIFF OFFICE, et ) al., ) ) Defendants. )

MEMORANDUM AND ORDER

This is a pro se prisoners’ complaint under 42 U.S.C. § 1983 purportedly brought by over two dozen Plaintiffs [Docs. 1, 7, and 8]. For the reasons set forth below, the Court will disallow class certification and permissive joinder of Plaintiffs in this action and order each Plaintiff wishing to proceed in a § 1983 suit to file an individual complaint and either pay the filing fee or submit the necessary documents to proceed in forma pauperis. Plaintiffs have classified their initial complaint as a class action, which the Court construes as a request for class certification. See Fed. R. Civ. P. 23(c)(1). To permit this action to proceed as a class action, the Court must be satisfied that a number of grounds are met, one of which is that “the representative parties will fairly and adequately protect the interests of the class.” Fed. R. Civ. P. 23(a)(4). However, pro se inmates are “not able adequately to represent [a] proposed class.” Heard v. Caruso, 351 F. App’x 1, 12 (6th Cir. 2009) (citing Oxendine v. Williams, 509 F.2d 1405, 1407 (4th Cir. 1975) (“Ability to protect the interests of the class depends in part on the quality of counsel, and we consider the competence of a layman representing himself to be clearly too limited to allow him to risk the rights of others.”)); see also Dodson v. Wilkinson, 304 F. App’x 434, 438 (6th Cir. 2008); Ziegler v. Michigan, 59 F. App’x 622, 624 (6th Cir. 2003); Palasty v. Hawk, 15 F. App’x 197, 200 (6th Cir. 2001); Howard v. Dougan, No. 99-2232, 2000 WL 876770, at *1 (6th Cir. June 23, 2000). Accordingly, the Court DENIES Plaintiffs’ motion for class certification. The Court otherwise notes that Rule 20(a)(1) of the Federal Rules of Civil Procedure allows the permissive joinder of plaintiffs in a single action 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)(1). While the joinder of parties is “strongly encouraged” for purposes of judicial economy and fairness where it is appropriate, United Mine Workers of America v. Gibbs, 383 U.S. 715, 724 (1966), courts have recognized that there are significant practical problems with allowing multiple prisoners to file a single complaint. See, e.g., McLaurin v. Bagley, No. 2:17-CV-11263, 2017 WL 1738031, at *5 (E.D. Mich. May 4, 2017) (noting that there are “‘pervasive impracticalities associated with multiple- plaintiff prisoner litigation, which militates against permissive joinder’” even where Rule 20(a)

permits it, including the “‘need for each plaintiff to sign every pleading, and the consequent possibilities that documents may be changed as they are circulated . . . . ’” as well as the fact that prisoner litigants are “notably transitory”) (citations omitted). The practical problems posed by multi-Plaintiff prisoner litigation is evident in this case. The Court notes that Plaintiff’s initial complaint contains only the signatures of Plaintiffs Steven Day, LaShawn L. Johnson, Robert Atkins, Jayland Woods, and James Tyler Porter [Doc. 1 p. 4, 5, 16, 27, 30, 33]. Plaintiffs thereafter filed an amended complaint that was signed only by Plaintiffs Johnson and Eddie Crippen [Doc. 7 p. 5, 7]. This complaint completely replaced the original complaint but did not include all the allegations of the original complaint [Compare Doc. 7 with Doc. 1]. See In re Refrigerant Compressors Antitrust Litig., 731 F.3d 586, 589 (6th Cir. 2013) (“An amended complaint supersedes an earlier complaint for all purposes.”) (citation omitted). A third amendment was filed on February 15, 2023, seeking to add multiple Plaintiffs and Defendants [Doc. 8]. However, Plaintiffs did not seek permission to file that amendment, which they were required to do by virtue of having already amended their complaint once, see

Fed. R. Civ. P. 15(a), and the amendment did not contain the signature of any Plaintiff [Doc. 8]. Therefore, not only was the filing submitted without leave of Court, but it was also submitted in contravention of Rule 11 of the Federal Rules of Civil Procedure. See Fed. R. Civ. P. 11(a) (requiring every pleading to be signed by a party personally if the party is unrepresented). Additionally, most of the Plaintiffs have not verified any of the facts alleged in the initial or amended complaint, and therefore, the Court cannot determine that their claims assert a right to relief “with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences” as required for them to proceed jointly in this matter. Fed. R. Civ. P. 20(a)(1). In fact, the opposite seems to be true, as some of Plaintiff Johnson’s claims arise

from incidents at the Washington County Detention Center, while the remaining Plaintiffs’ claims, though varied, are confined to incidents at the Knox County Detention Facility [See, generally Docs. 1, 7]. Moreover, given the significant practical issues arising out of prisoners filing joint complaints, which is apparent from the filings so far in this case, the Court finds that even if Rule 20(a) permitted joinder of over two dozen Plaintiffs, it would be impractical and inefficient for the Court to allow them to do so in this case. As such, Plaintiffs are NOTIFIED that they will not be allowed to proceed jointly in this action. While the Court may sever this action to allow each Plaintiff to proceed separately, Fed. R. Civ. P. 21, the Court has several concerns doing so sua sponte. First, a significant portion of the filings in this case are written in the hand of Plaintiff LaShawn Johnson [See Docs 1, 5, 6, 7, 8, 9], and given the absence of signatures for most of the Plaintiffs, it is not apparent that they all have actually consented to suit. Second, because joinder has been disallowed, each Plaintiff will be solely responsible for the entire filing fee of an individual action. The Court is mindful that one or more Plaintiffs may not wish to pursue an individual action in light of that fact. Third, a

lawsuit is initiated by filing a complaint. Fed. R. Civ. P. 3

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Related

United Mine Workers of America v. Gibbs
383 U.S. 715 (Supreme Court, 1966)
Walker v. Armco Steel Corp.
446 U.S. 740 (Supreme Court, 1980)
Dodson v. Wilkinson
304 F. App'x 434 (Sixth Circuit, 2008)
Lamont Heard v. Patricia Caruso
351 F. App'x 1 (Sixth Circuit, 2009)
Palasty v. Hawk
15 F. App'x 197 (Sixth Circuit, 2001)
Ziegler v. Michigan
59 F. App'x 622 (Sixth Circuit, 2003)
Oxendine v. Williams
509 F.2d 1405 (Fourth Circuit, 1975)

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Bluebook (online)
Day v. Knox County Sheriff Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/day-v-knox-county-sheriff-office-tned-2023.