Allstate Fire & Casualty Insurance Company v. Electrolux Home Products, Inc., 1:16-cv-02080

Allstate insurers sued Electrolux on subrogation for two residential fires (losses in Aug. and Nov. 2014) allegedly caused by Electrolux "ball-hitch" dryers; plaintiffs seek recovery under strict products liability theories.
Plaintiffs allege the two dryers shared common structural features and a common design/redesign process by Electrolux that made plastic components defectively designed.
Electrolux moved to sever and dismiss one claim under Fed. R. Civ. P. 21, arguing the two subrogation claims are misjoined because they involve different dryer models, different failure modes, and distinct facts that would make joint litigation inefficient and prejudicial.
Plaintiffs contended joinder is proper under Fed. R. Civ. P. 20 because both claims arise from the defendant’s allegedly defective product design and present common legal and factual questions (e.g., whether the plastic design rendered the dryers unreasonably dangerous).
The court evaluated permissive joinder standards (transaction/occurrence nexus and common questions of law or fact), compared the case to drug-liability joinder authorities, and considered potential prejudice and discovery burdens.
The court concluded common issues (design defect, consumer expectations, risk-benefit analysis) predominate and denied Electrolux’s motion to sever and dismiss.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the two subrogation claims arise out of the same transaction/occurrence for joinder under Rule 20	Both claims stem from Electrolux’s defectively designed dryers and shared redesign/process issues	Claims involve different models and failure modes; not the same transaction/occurrence	Claims arise from a logically related series of events; joinder permitted
Whether common questions of law or fact exist among plaintiffs	Both require proof of design defect, consumer-expectation and risk-benefit inquiries	Different factual causes will dominate and preclude common proof	Common legal/factual issues (design defect standards) exist and support joinder
Whether drug-case precedents showing stricter joinder rules control here	Joinder is broader outside drug cases; no individualized medical-history concerns	Points to stricter standards in prescription-drug joinder cases	Drug-case stricter rule inapplicable; product-design allegations here are different
Whether defendant would be prejudiced or unduly burdened such that severance is required	N/A (plaintiffs sought joinder)	Joinder would make discovery unwieldy and prejudice Electrolux at trial	Alleged prejudice and discovery burdens are speculative and premature; severance denied

Chrysler Credit Corp. v. Country Chrysler, Inc., 928 F.2d 1509 (10th Cir. 1991) (severance under Rule 21 creates a separate case and district court has broad discretion)
United Mine Workers of Am. v. Gibbs, 383 U.S. 715 (U.S. 1966) (Federal Rules favor broad joinder to promote convenience and efficiency)
DIRECTV, Inc. v. Barrett, 220 F.R.D. 630 (D. Kan. 2004) (transaction/occurrence standard for permissive joinder and logical relationship test)
White v. Caterpillar, Inc., 867 P.2d 100 (Colo. App. 1993) (Colorado law recognizes design, manufacturing, and failure-to-warn theories and applies consumer-expectation and risk-benefit tests)