Robert White, et al. v. Department of Corrections, et al.

CourtDistrict Court, S.D. New York
DecidedOctober 30, 2025
Docket1:25-cv-08711
StatusUnknown

This text of Robert White, et al. v. Department of Corrections, et al. (Robert White, et al. v. Department of Corrections, et al.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert White, et al. v. Department of Corrections, et al., (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ROBERT WHITE, et al., Plaintiffs, 1:25-CV-8711 (LTS) -against- ORDER TO SEVER AND OPEN NEW CIVIL ACTIONS DEPARTMENT OF CORRECTIONS, et al., Defendants. LAURA TAYLOR SWAIN, Chief United States District Judge: Robert White, who is currently held in the Otis Bantum Correctional Center (“OBCC”) on Rikers Island, filed this action pro se in which he asserts claims arising out of an incident that allegedly occurred in the OBCC on August 29, 2025. The complaint initiating this action seems to allege that White and 27 other then-OBCC prisoners were forced to undergo “un[acc]eptable[,] mandatory[,] random, or orchestrated high specialized (stripped naked searches) by force.” (ECF 1, at 6.) It lists the names of White and of the 27 other prisoners as the named plaintiffs, though only White has signed the complaint.1 For the reasons set forth below, the Court directs the Clerk of Court to: (1) sever from this action, under Rule 21 of the Federal Rules of Civil Procedure, the claims of those prisoners, other than White, who are named as plaintiffs in this action; (2) open a new civil action for each of those plaintiffs, other than White, who will now be the sole plaintiff in this action; and (3) file a copy of the complaint from this action and a copy of this order in each of the newly opened actions.

1 In addition to being the only prisoner to have signed the complaint, White is the only prisoner to have filed a signed in forma pauperis (“IFP”) application and prisoner authorization. (ECF 2 & 3.) The Court has granted White IFP status. (ECF 5.) DISCUSSION Under Rule 20 of the Federal Rules of Civil Procedure (“Rule 20”), multiple plaintiffs may join in one action if: (1) they assert any right to relief arising out of the same transaction, occurrence, or series of occurrences; and (2) any question of law or fact in common to all the plaintiffs will arise in the action. Fed. R. Civ. P. 20(a); Kalie v. Bank of Am. Corp., No. 1:12-CV-

9192 (PAE), 2013 WL 4044951, at *3 (S.D.N.Y. Aug. 9, 2013) (courts “look to the logical relationship between the claims and determine ‘whether the essential facts of the various claims are so logically connected that considerations of judicial economy and fairness dictate that all the issues be resolved in one lawsuit’” (quoting United States v. Aquavella, 615 F.2d 12, 22 (2d Cir. 1979))). Under Rule 21 of the Federal Rules of Civil Procedure (“Rule 21”), courts have the authority to sever claims, even without a finding that joinder of such claims would be improper. See Fed. R. Civ. P. 21. Generally, if joinder “will not foster the objectives of the rule, but will result in prejudice, expense or delay,” Wright & Miller, Fed. Prac. & Proc. § 1652 (3d ed.)

(footnote omitted), a court may sever a claim, see Wyndham Assoc. v. Bintliff, 398 F.2d 614, 618 (2d Cir. 1968) (Rule 21 “authorizes the severance of any claim, even without a finding of improper joinder, where there are sufficient other reasons for ordering a severance”); Ghaly v. U.S. Dep’t of Agric., 228 F. Supp. 2d 283, 292 (S.D.N.Y. 2002) (noting that “district courts have broad discretion to decide whether joinder is appropriate, even when the requirements of Rule 20(a) have been met” (citation omitted)). In determining whether to order severance of claims, courts consider the requirements of Rule 20 and additional factors, “including (1) whether severance will serve judicial economy; (2) whether prejudice to the parties would be caused by severance; and (3) whether the claims involve different witnesses and evidence.” Kehr v. Yamaha Motor Corp., 596 F. Supp. 2d 821, 826 (S.D.N.Y. 2008) (considering motion to sever under Rules 20 and 21); see also Laureano v. Goord, No. 1:06-CV-7845 (SHS) (RLE), 2007 WL 2826649, at *8 (S.D.N.Y. Aug. 31, 2007) (noting that, when considering severance, “courts should be guided by ‘considerations of convenience, avoidance of prejudice to the parties, and efficiency’” (quoting Hecht v. City of

New York, 217 F.R.D. 148, 150 (S.D.N.Y. 2003)), report & recommendation adopted, 2007 WL 2852770 (S.D.N.Y. Sept. 28, 2007). The Court finds that, in the interests of judicial economy, the claims brought by the plaintiffs other than White should be severed from this action, under Rule 21, because the practical realities of managing this pro se multi-prisoner litigation militate against adjudicating the plaintiffs’ claims in one action. First, as pro se litigants, each plaintiff may only appear on his or her own behalf; none may appear as an attorney for the others. See United States ex rel. Mergent Servs. v. Flaherty, 540 F.3d 89, 92 (2d Cir. 2008) (“[A]n individual who is not licensed as an attorney ‘may not appear on another person’s behalf in the other’s cause’” (citations omitted)); Iannaccone v. Law,

142 F.3d 553, 558 (2d Cir. 1998) (“[B]ecause pro se means to appear for one’s self, a person may not appear on another person’s behalf in the other’s cause”). Although it appears that White filed the complaint, he does not allege that he is an attorney, and therefore, he cannot represent the interests of the 27 other plaintiffs. Second, Rule 11(a) of the Federal Rules of Civil Procedure requires that every pleading, written motion, or other paper be signed by every party personally who is unrepresented. Fed. R. Civ. P. 11(a). During this action, each plaintiff will be required to sign every document submitted. But because of the transitory nature of a pretrial detention facility, such as the OBCC, where one or more of the plaintiffs could be released or transferred at any time, at least some of the plaintiffs will be likely unable to sign future documents. Finally, because of security concerns related to correspondence and face-to-face communications between detained individuals, the plaintiffs will have, at best, only a very

limited opportunity to discuss case strategy, share discovery, or even provide each other with copies of the submissions that they file with the court. These circumstances will result in piecemeal submissions, delays, and missed deadlines. See Perkins v. City of New York, No. 1:14- CV-3779 (WHP), 2014 WL 5369428, at *1 (S.D.N.Y. Oct. 20, 2014) (finding that a multi- prisoner-plaintiff civil action should be severed, under Rule 21, into individual civil actions based on the many infirmities in the complaint, security considerations, and the plaintiffs’ likely inability to jointly litigate one civil action because they are housed in different facilities or given limited opportunities to associate). For these reasons, the Court concludes that allowing this civil action to proceed as a multi-plaintiff civil action would not be fair to all of the plaintiffs and would not achieve judicial

economy. Allowing each plaintiff to proceed separately will facilitate the fair and efficient disposition of the litigation.

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Related

Proceedings in forma pauperis
28 U.S.C. § 1915(a)(3)

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Bluebook (online)
Robert White, et al. v. Department of Corrections, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-white-et-al-v-department-of-corrections-et-al-nysd-2025.