Hinchee v. Reed

CourtDistrict Court, W.D. Virginia
DecidedJanuary 15, 2025
Docket7:24-cv-00721
StatusUnknown

This text of Hinchee v. Reed (Hinchee v. Reed) is published on Counsel Stack Legal Research, covering District Court, W.D. Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hinchee v. Reed, (W.D. Va. 2025).

Opinion

CLERK'S OFFICE U.S. DIST. COUF AT ROANOKE, VA IN THE UNITED STATES DISTRICT COURT FILED FOR THE WESTERN DISTRICT OF VIRGINIA January 15, 2025 ROANOKE DIVISION RAA. AUSTIN, □□□□□ *SEDUTY CLERK Lawrence Edward Hinchee, Jr., ) Plaintiff, v. Civil Action No. 7:24-cv-00721 Director John Reed, ef a/, Defendants.

ORDER Lawrence Edward Hinchee, Jr., a Virginia inmate proceeding pro se, filed this civil action pursuant to 42 U.S.C. § 1983. The complaint alleges that 26 defendants violated a variety of laws and constitutional rights. The claims arise from events that allegedly occurred over approximately two years at various facilities and involve various departments. (Compl. (Dkt 1).) Most of the claims have no commonality with the other claims. Hinchee also submitted 188 pages of additional materials along with his complaint, consisting of his journal, correspondence, and documents related to administrative exhaustion of his grievances. The court will sever Hinchee’s claims into several lawsuits for the reasons explained below. I. Standards for Joinder and Severance A plaintiff may join defendants in the same action only if “any right to relief is asserted against them jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences” and “any question of law or fact common to all defendants will arise in the action.” Fed. R. Civ. P.

20(a)(2)(A), (B). “Under Rule 20, reasonably related claims may be tried together.” Sykes v. Bayer Pharms. Corp., 548 F. Supp. 2d 208, 218 (E.D. Va. 2008) (cleaned up). However, “Rule 20 does not authorize a plaintiff to add claims against different parties that present

entirely different factual and legal issues.” Id. (cleaned up). “[W]here claims arise out of different transactions and do not involve all defendants, joinder of the claims in one lawsuit is not proper.” Moore v. Squire, No. 7:23-cv-00439, 2023 WL 5095696, at *1 (W.D. Va. Aug. 9, 2023). Additionally, the court concludes that allowing all of Hinchee’s claims to proceed in a single suit would make that lawsuit unwieldy and inefficient and would effectively

allow Hinchee to challenge different aspects of his incarceration and unrelated actions by various defendants in a single omnibus suit, which violates the aims of the Prison Litigation Reform Act (“PLRA”). “Congress enacted the PLRA with the principal purpose of deterring frivolous prisoner litigation by instituting economic costs for prisoners wishing to file civil claims.” Charron v. Allen, 37 F.4th 483, 486 (8th Cir. 2022). Courts have emphasized that “unrelated claims against different defendants belong in

separate lawsuits, not only ‘to prevent the sort of morass’ produced by multi-claim, multi- defendant suits . . . , but also to ensure that prisoners pay all fees required under the Prison Litigation Reform Act.” Owens v. Hinsley, 635 F.3d 950, 952 (7th Cir. 2011) (quoting George v. Smith, 507 F.3d 605, 607 (7th Cir. 2007)). Although “[m]isjoinder of parties is not a ground for dismissing an action,” a district court “may at any time, on just terms, add or drop a party” or “sever any claim

against a party.” Fed. R. Civ. P. 21. Under Rule 21, district courts have “virtually unfettered discretion in determining whether or not severance is appropriate.” 17th St. Assocs., LLP v. Markel Int’l Ins. Co., 373 F. Supp. 2d 584, 598 n.9 (E.D. Va. 2005). Complaints that contain a hodgepodge of allegations against multiple defendants “should

be rejected, either by severing the action into separate lawsuits or by dismissing improperly joined defendants.” Owens, 635 F.3d at 952 (cleaned up). Here, the complaint alleges different claims and unrelated factual allegations, such that it would not be efficient or otherwise appropriate to allow Hinchee to prosecute all of his claims in a single case. See Moore, 2023 WL 5095696, at *1; Equal Rights Ctr. v. Equity Residential, 483 F. Supp. 2d 482, 489 (D. Md. 2007) (noting that, in determining whether

severance is proper, courts may consider whether the issues to be severed are significantly different from one another, will require different witnesses or different documentary proof, and the potential prejudice to any party). II. Hinchee’s Claims Will Be Severed Based upon a review of the complaint, the court concludes that Hinchee’s claims and defendants are misjoined. See Fed. R. Civ. P. 18, 20. Accordingly, the court will

exercise its discretion to sever Hinchee’s claims into separate lawsuits, attempting to group together like claims and/or claims against the same defendants in order to promote judicial efficiency and ensure that the claims can be addressed in an orderly fashion. Along with a copy of this Order, Hinchee’s complaint (Dkt. 1) shall be filed as the opening document in each of the new lawsuits. Hinchee is advised that the court does not need evidence or supporting documentation when a claim is initiated, and so the court will not order the

duplication in each new case of the 188 page of exhibits submitted with Hinchee’s original complaint. If Hinchee wishes to base his claims in any action upon any content in or facts contained in the 188 pages of exhibits, he is advised that he must specify the content or facts in an amended complaint.

The new lawsuits directed in this order will be conditionally filed, and Hinchee will be required to return a consent to fee form in each of the new cases, based on the in forma pauperis application he has provided in this case. The amount of the required initial partial payment will be the same in the new cases as it was for this case: $46.32. In the alternative to submitting the consent to collection of fees form and authorizing the initial partial payment of the filing fees, Hinchee may elect not to proceed with any of the cases by

moving to voluntarily dismiss any such case. Additionally, if Hinchee fails to return the consent to fee form in a new case, the new case will be dismissed without prejudice. The fact that the court is allowing the filing of Hinchee’s claims as separate actions is not a finding that he has stated any meritorious claim for relief under 42 U.S.C. § 1983 or any other valid claim. The court may file subsequent orders related to deficiencies in any of Hinchee’s cases.

III. Directions Regarding Severance It is hereby ORDERED that this case is SEVERED into a total of eleven cases (this case and ten new cases). The Clerk is DIRECTED to open ten new cases and to conditionally file a copy of the original complaint (Dkt. 1) in the new cases, along with a copy of this Order, with each case as described below. In each new civil action, the Clerk is further DIRECTED to include in the first docket entry the paragraph numbers of the original

complaint that will constitute the subject matter of that particular case. The Clerk is further DIRECTED to docket Hinchee’s Statement of Assets and Prisoner Trust Account Report (Dkt.

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Related

Owens v. Hinsley
635 F.3d 950 (Seventh Circuit, 2011)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Sykes v. Bayer Pharmaceuticals Corp.
548 F. Supp. 2d 208 (E.D. Virginia, 2008)
Equal Rights Center v. Equity Residential
483 F. Supp. 2d 482 (D. Maryland, 2007)
Kenneth Charron v. Larry Allen
37 F.4th 483 (Eighth Circuit, 2022)

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Hinchee v. Reed, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hinchee-v-reed-vawd-2025.