Lauren Anderson v. Doe Employees of the Minnehaha County Juvenile Detention Center, Minnehaha County, South Dakota, State of South Dakota, a Political Subdivision; Payten Van Roekel v. Doe Employees of the Minnehaha County Juvenile Detention Center, Minnehaha County, South Dakota, State of South Dakota, a Political Subdivision

• Court: District Court, D. South Dakota
• Decided: February 23, 2026
• Docket: 4:25-cv-04023
• Status: Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA SOUTHERN DIVISION

LAUREN ANDERSON, 4:25-CV-04025-RAL Plaintiff, ORDER GRANTING JOINT MOTION TO vs. CONSOLIDATE DOE EMPLOYEES OF THE MINNEHAHA COUNTY JUVENILE DETENTION CENTER, MINNEHAHA COUNTY, SOUTH DAKOTA, STATE OF SOUTH DAKOTA, A POLITICAL SUBDIVISION, Defendants.

PAYTEN VAN ROEKEL, 4:25-CV-04023-RAL Plaintiff, VS. DOE EMPLOYEES OF THE MINNEHAHA COUNTY JUVENILE DETENTION CENTER, MINNEHAHA COUNTY, SOUTH DAKOTA, STATE OF SOUTH DAKOTA, A POLITICAL SUBDIVISION, Defendants.

The parties have moved jointly to consolidate Anderson _v. Doe Employees of the Minnehaha County Juvenile Detention, Case No. 4:25-cv-4025-RAL, and Van Roekel v. Doe Employees of the Minnehaha County Juvenile Detention, Case No. 4:25-cv-4023-RAL. Doc. 52 in No. 4:25-cv-4025; Doc. 56 in No. 4:25-cv-4023. “If actions before the court involve a common

question of law or fact,” Federal Rule of Civil Procedure 42(a) grants a court the discretion to “join for hearing or trial any or all matters at issue in the actions,” “consolidate the actions,” or “issue any other orders to avoid unnecessary cost or delay.” Fed. R. Civ. P. 42(a). See also Enter. Bank v. Saettele, 21 F.3d 233, 236 (8th Cir. 1994) (noting “a common issue of law or fact is a prerequisite to consolidation’’); Horizon Asset Mgmt. Inc. v. H & R Block, Inc., 580 F.3d 755, 768 (8th Cir. 2009) (concluding that consolidation was not an abuse of discretion where “[t]he actions involved common parties, overlapping legal issues, and related factual scenarios, and the consolidation itself did not cause unfair prejudice”). Both pending actions involve common issues of law and fact as well as common defenses. This Court finds that consolidation will promote judicial economy as the parties have shown that consolidation satisfies the factors of Rule 42. The parties have reserved the right to seek separate trials under Rule 42(b). For the foregoing reasons, it is hereby ORDERED that the Joint Motions to Consolidate, Doc. 52 in No. 4:25-cv-4025 and Doc. 56 in No. 4:25-cv-4023, are granted. It is further ORDERED that Anderson v. Doe, Case No. 4:25-cv-4025, is designated as the lead case. DATED this 23rd day of February, 2026. BY THE COURT:

_ Ghali ROBERTO A. LANGE CHIEF JUDGE