(PC) Adkins v. Ditomas

CourtDistrict Court, E.D. California
DecidedJune 27, 2025
Docket2:22-cv-01650
StatusUnknown

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

Bluebook
(PC) Adkins v. Ditomas, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 DuPREE LAMONT ADKINS, No. 2:22-CV-1650-DMC-P 12 Plaintiff, 13 v. ORDER 14 DITOMOAS, et al., and 15 Defendants. FINDINGS AND RECOMMENDATIONS 16 17 Plaintiff, a prisoner proceeding pro se, brings this civil rights action pursuant to 18 42 U.S.C. § 1983. Pending before the Court is Defendants’ motion to sever unrelated claims. See 19 ECF No. 19. Plaintiff has not filed an opposition. 20 Federal Rule of Civil Procedure 18(a) limits the joinder of claims, whereas Federal 21 Rule of Civil Procedure 20(a) limits the joinder of parties in a single lawsuit. Rule 18(a) states: 22 “A party asserting a claim . . . may join, as independent or alternative claims, as many claims as it 23 has against an opposing party.” Rule 20(a)(2) states: “[p]ersons . . . may be joined in one action 24 as defendants if: (A) any right to relief is asserted against them jointly, severally, or in the 25 alternative with respect to or arising out of the same transaction, occurrence, or series of 26 transactions or occurrences; and (B) any question of law or fact common to all defendants will 27 arise in the action.” Courts have recognized that when multiple parties are named, the analysis 28 under Rule 20 precedes that under Rule 18. See Herndon v. Mich. Dep’t of Corr., 2021 WL 1 1559156 at *2 (W.D. Mich. April 12, 2021).

2 Rule 20 deals solely with joinder of parties and becomes relevant only when there is more than one party on one or both sides of the action. It 3 is not concerned with joinder of claims, which is governed by Rule 18. Therefore, in actions involving multiple defendants Rule 20 operates 4 independently of Rule 18 . . . . Despite the broad language of Rule 18(a), plaintiff may join 5 multiple defendants in a single action only if plaintiff asserts at least one claim to relief against each of them that arises out of the same transaction 6 or occurrence and presents questions of law or fact common to all.

7 Id. (citing 7 Charles Allen Wright & Arthur R. Miller, Federal Practice and Procedure § 1655 (3d ed. 2001), quoted in Proctor v. Applegate, 661 F. 8 Supp. 2d 743, 778 (E.D. Mich. 2009), and Garcia v. Munoz, No. 08-1648, 2008 WL 2064476, at *3 (D.N.J. May 14, 2008); see also United States v. 9 Mississippi, 380 U.S. 128, 142–43 (1965)). 10 Permissive joinder under Rule 20 “is to be construed liberally in order to promote 11 trial convenience and to expedite the final determination of disputes, thereby preventing multiple 12 lawsuits.” League to Save Lake Tahoe v. Tahoe Reg’l Planning Agency, 558 F.2d 914, 917 (9th 13 Cir. 1997). The purpose of Rule 20 is to address the “broadest possible scope of action consistent 14 with fairness to the parties; joinder of claims, parties, and remedies is strongly encouraged.” 15 United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 724 (1966). Rule 20 sets forth two specific 16 requirements for permissive joinder: “(1) a right to relief must be asserted by, or against, each 17 plaintiff or defendant relating to or arising out of the same transaction or occurrence or series of 18 transactions or occurrences; and (2) some question of law or fact common to all parties must arise 19 in the action.” Desert Empire Bank v. Ins. Co. of N. Am., 623 F.2d 1371, 1375 (9th Cir. 1980) 20 (citing League to Save Lake Tahoe, 558 F.2d at 917). 21 As to the first requirement, courts assess the facts of each case individually to 22 determine whether joinder is sensible considering the underlying policies of permissive party 23 joinder. Coughlin v. Rogers, 130 F.3d 1348, 1350 (9th Cir. 1997). “The ‘same transaction’ 24 requirement of Rule 20 refers to ‘similarity in the factual background of a claim; claims that arise 25 out of a systematic pattern of events’ and have a ‘very definite logical relationship.’” Hubbard v. 26 Hougland, 2010 WL 1416691, at *7 (E.D. Cal. Apr. 5, 2010) (quoting Bautista v. Los Angeles 27 County, 216 F.3d 837, 842-843 (9th Cir. 2000)). Additionally, “the mere fact that all [of a 28 plaintiff’s] claims arise under the same general law does not necessarily establish a common 1 question of law or fact.” Coughlin, 130 F.3d at 1351. 2 As to the second requirement, commonality under Rule 20 is not a particularly 3 stringent test. See Johnson v. Shaffer, 2013 WL 140115, at *2 (E.D. Cal. Jan. 10, 2013) (citing 4 Bridgeport Music, Inc. v. 11 C Music, 202 F.R.D. 229, 231 (M.D. Tenn. 2001)). The Rule 5 requires only a single common question, not multiple common questions. Fed. R. Civ. P. 20 (“any 6 question of law or fact common to . . .”). “The common question may be one of fact or of law and 7 need not be the most important or predominant issue in the litigation.” Johnson, 2013 WL 8 140115, at *2 (citing Mosley v. Gen. Motors Corp., 497 F.2d 1330, 1333 (8th Cir. 1974)). 9 And even if a court finds that the requirements have been met, “a district court must examine 10 whether permissive joinder would ‘comport with principles of fundamental fairness’ or would 11 result in prejudice to either side.” Coleman v. Quaker Oats Company, 232 F.3d 1271, 1296 (9th 12 Cir. 2000) (citing Desert Empire Bank, 623 F.2d at 1375 (finding that the district court did not 13 abuse its discretion when it severed certain plaintiff’s claims without finding improper joinder)). 14 Under Rule 20(b), the district court may sever claims or parties to avoid prejudice. 15 Fed. R. Civ. P. 20(b). Courts have also exercised their discretion to sever where “[i]nstead of 16 making the resolution of [the] case more efficient . . . joinder would instead confuse and 17 complicate the issues for all parties involved.” Rodriguez v. Tilton, 2013 WL 1163796, at *6 18 (E.D. Cal. Mar. 20, 2013) (quoting Wynn v. Nat’l Broad. Co., 234 F. Supp. 2d 1067, 1088 (C.D. 19 Cal. 2002) (finding that even where Rule 20 requirements for joinder are satisfied, the court may 20 exercise its discretion “to sever for at least two reasons: (1) to prevent jury confusion and judicial 21 inefficiency, and (2) to prevent unfair prejudice to the [defendants]”)) (citing Coleman, 232 F.3d 22 at 1350). 23 If, however, the requirements for permissive joinder are not satisfied, courts may 24 look to Rule 21. Coughlin, 130 F.3d at 1350. Under Rule 21, where a court finds misjoinder, it 25 may “drop a party” or “sever any claim against a party” as it considers just, but it may not dismiss 26 the entire action. Fed. R. Civ. P. 21. In other words, where there is misjoinder, a court “has two 27 remedial options: (1) misjoined parties may be dropped ‘on such terms as are just’; or (2) any 28 claims against misjoined parties ‘may be severed and proceeded with separately.’” DirecTV, Inc. 1 v. Leto,

Related

United States v. Mississippi
380 U.S. 128 (Supreme Court, 1965)
United Mine Workers of America v. Gibbs
383 U.S. 715 (Supreme Court, 1966)
George v. Smith
507 F.3d 605 (Seventh Circuit, 2007)
Wynn v. National Broadcasting Co., Inc.
234 F. Supp. 2d 1067 (C.D. California, 2002)
Brennan v. Kulick
407 F.3d 603 (Third Circuit, 2005)
DirecTV, Inc. v. Leto
467 F.3d 842 (Third Circuit, 2006)
Coughlin v. Rogers
130 F.3d 1348 (Ninth Circuit, 1997)
Bautista v. Los Angeles County
216 F.3d 837 (Ninth Circuit, 2000)
Bridgeport Music, Inc. v. 11C Music
202 F.R.D. 229 (M.D. Tennessee, 2001)

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Bluebook (online)
(PC) Adkins v. Ditomas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pc-adkins-v-ditomas-caed-2025.