Mosley v. General Motors Corp.
497 F.2d 1330 (8th Cir. 1974)
Facts:
- Mosley and 10 other defendants worked for GM.
Procedural History:
- Each plaintiff filed a complaint with the EEOC, which in turn notified them that they had the right to institute a civil action in federal court.
- District court ruled that the 10 counts should be severed into separate lawsuits
Reversed and remanded.
Contentions of parties:
¶: GM engaged in unlawful employment practices by discriminating against African Americans, and the Union failed to pursue their grievances.
Issue:
Whether the district court abused its discretion in declaring that joining plaintiffs’ cases was unmanageable under Rule 20.
Holding:
The district court abused its discretion in declaring that joining plaintiffs’ cases was unmanageable under Rule 20 because their right of relief arose from the same transaction, occurrence, series of transactions or occurrences, and they share a common question of fact.
Rule:
For plaintiffs to be joined in a lawsuit, (1) the right of relief arose from the same transaction, occurrence, series of transactions or occurrences, and (2) they share a common question of law or fact.
Rule(s) of Law:
Rule 20:
Rule 20. Permissive Joinder of Parties
(a) Persons Who May Join or Be Joined.
(1) Plaintiffs. Persons may join in one action as plaintiffs if:
(A) they assert any right to relief jointly, severally, or in the alternative with respect to or arising out of the same transaction, occurrence, or series of transactions or occurrences; and
(B) any question of law or fact common to all plaintiffs will arise in the action.
(2) Defendants. Persons–as well as a vessel, cargo, or other property subject to admiralty process in rem–may be joined in one action as defendants if:
(A) 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
(B) any question of law or fact common to all defendants will arise in the action.
(3) Extent of Relief. Neither a plaintiff nor a defendant need be interested in obtaining or defending against all the relief demanded. The court may grant judgment to one or more plaintiffs according to their rights, and against one or more defendants according to their liabilities.
(b) Protective Measures. The court may issue orders–including an order for separate trials–to protect a party against embarrassment, delay, expense, or other prejudice that arises from including a person against whom the party asserts no claim and who asserts no claim against the party.>
US v. Mississippi
Court’s Order:
Reversed and remanded.