(PC) Mendoza v. Matteson

District Court, E.D. California·Decided June 13, 2025·No. 2:22-cv-01136·Unknown

Opinion

1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT 9 FOR THE EASTERN DISTRICT OF CALIFORNIA 10 11 JOHN MENDOZA No. 2:22-CV-1136-KJM-DMC-P 12 Plaintiff, 13 v. FINDINGS AND RECOMMENDATIONS 14 G. MATTESON, et al., 15 Defendants. 16 17 Plaintiff, who is proceeding pro se, brings this civil rights action pursuant to 42 18 U.S.C. § 1983. Pending before the Court is Defendants' motion to sever and dismiss misjoined 19 claims under Federal Rules of Civil Procedure 20(a) and 21. See ECF No. 20. Plaintiff has filed 20 an opposition. See ECF No. 24. Defendants have filed a reply. See ECF No. 25. For the reasons 21 discussed below, the Court finds that Defendants' motion should be granted in part and denied in 22 part. 23 Federal Rule of Civil Procedure 18(a) limits the joinder of claims, whereas Federal 24 Rule of Civil Procedure 20(a) limits the joinder of parties in a single lawsuit. Rule 18(a) states: 25 “A party asserting a claim . . . may join, as independent or alternative claims, as many claims as it 26 has against an opposing party.” Rule 20(a)(2) states: “[p]ersons . . . may be joined in one action 27 as defendants if: (A) any right to relief is asserted against them jointly, severally, or in the 28 alternative with respect to or arising out of the same transaction, occurrence, or series of 1 transactions or occurrences; and (B) any question of law or fact common to all defendants will 2 arise in the action.” Courts have recognized that when multiple parties are named, the analysis 3 under Rule 20 precedes that under Rule 18. See Herndon v. Mich. Dep’t of Corr., 2021 WL 4 1559156 at *2 (W.D. Mich. April 12, 2021).

5 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. 6 It is not concerned with joinder of claims, which is governed by Rule 18. Therefore, in actions involving multiple defendants Rule 20 operates 7 independently of Rule 18 . . . . Despite the broad language of Rule 18(a), plaintiff may join 8 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 9 or occurrence and presents questions of law or fact common to all.

10 Id. (citing 7 Charles Allen Wright & Arthur R. Miller, Federal Practice and Procedure § 1655 (3d ed. 2001), quoted in Proctor v. Applegate, 661 F. 11 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. 12 Mississippi, 380 U.S. 128, 142–43 (1965)). 13 Permissive joinder under Rule 20 “is to be construed liberally in order to promote 14 trial convenience and to expedite the final determination of disputes, thereby preventing multiple 15 lawsuits.” League to Save Lake Tahoe v. Tahoe Reg’l Planning Agency, 558 F.2d 914, 917 (9th 16 Cir. 1997). The purpose of Rule 20 is to address the “broadest possible scope of action consistent 17 with fairness to the parties; joinder of claims, parties, and remedies is strongly encouraged.” 18 United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 724 (1966). Rule 20 sets forth two specific 19 requirements for permissive joinder: “(1) a right to relief must be asserted by, or against, each 20 plaintiff or defendant relating to or arising out of the same transaction or occurrence or series of 21 transactions or occurrences; and (2) some question of law or fact common to all parties must arise 22 in the action.” Desert Empire Bank v. Ins. Co. of N. Am., 623 F.2d 1371, 1375 (9th Cir. 1980) 23 (citing League to Save Lake Tahoe, 558 F.2d at 917). 24 As to the first requirement, courts assess the facts of each case individually to 25 determine whether joinder is sensible in light of the underlying policies of permissive party 26 joinder. Coughlin v. Rogers, 130 F.3d 1348, 1350 (9th Cir. 1997). “The ‘same transaction’ 27 requirement of Rule 20 refers to ‘similarity in the factual background of a claim; claims that arise 28 out of a systematic pattern of events’ and have a ‘very definite logical relationship.’” Hubbard v. 1 Hougland, 2010 WL 1416691, at *7 (E.D. Cal. Apr. 5, 2010) (quoting Bautista v. Los Angeles 2 County, 216 F.3d 837, 842-843 (9th Cir. 2000)). Additionally, “the mere fact that all [of a 3 plaintiff’s] claims arise under the same general law does not necessarily establish a common 4 question of law or fact.” Coughlin, 130 F.3d at 1351. 5 As to the second requirement, commonality under Rule 20 is not a particularly 6 stringent test. See Johnson v. Shaffer, 2013 WL 140115, at *2 (E.D. Cal. Jan. 10, 2013) (citing 7 Bridgeport Music, Inc. v. 11 C Music, 202 F.R.D. 229, 231 (M.D. Tenn. 2001)). The Rule 8 requires only a single common question, not multiple common questions. Fed. R. Civ. P. 20 9 (“any question of law or fact common to . . .”). “The common question may be one of fact or of 10 law and need not be the most important or predominant issue in the litigation.” Johnson, 2013 11 WL 140115, at *2 (citing Mosley v. Gen. Motors Corp., 497 F.2d 1330, 1333 (8th Cir. 1974)). 12 And even if a court finds that the requirements have been met, “a district court must examine 13 whether permissive joinder would ‘comport with principles of fundamental fairness’ or would 14 result in prejudice to either side.” Coleman v. Quaker Oats Company, 232 F.3d 1271, 1296 (9th 15 Cir. 2000) (citing Desert Empire Bank, 623 F.2d at 1375 (finding that the district court did not 16 abuse its discretion when it severed certain plaintiff’s claims without finding improper joinder)). 17 Under Rule 20(b), the district court may sever claims or parties in order to avoid 18 prejudice. Fed. R. Civ. P. 20(b). Courts have also exercised their discretion to sever where 19 “[i]nstead of making the resolution of [the] case more efficient . . . joinder would instead confuse 20 and complicate the issues for all parties involved.” Rodriguez v. Tilton, 2013 WL 1163796, at *6 21 (E.D. Cal. Mar. 20, 2013) (quoting Wynn v. Nat’l Broad. Co., 234 F. Supp. 2d 1067, 1088 (C.D. 22 Cal. 2002) (finding that even where Rule 20 requirements for joinder are satisfied, the court may 23 exercise its discretion “to sever for at least two reasons: (1) to prevent jury confusion and judicial 24 inefficiency, and (2) to prevent unfair prejudice to the [defendants]”)) (citing Coleman, 232 F.3d 25 at 1350). 26 / / / 27 / / / 28 / / / 1 If, however, the requirements for permissive joinder are not satisfied, courts may 2 look to Rule 21. Coughlin, 130 F.3d at 1350. Under Rule 21, where a court finds misjoinder, it 3 may “drop a party” or “sever any claim against a party” as it considers just, but it may not dismiss 4 the entire action. Fed. R. Civ. P.

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