(PC) Dews v. State Water System I.D. 1510802, 1:12-cv-01398

Dews, a state prisoner, filed a 42 U.S.C. § 1983 action in the Eastern District of California on August 17, 2012.
In November 2012, inmates Walker and Adderley moved to join as co-plaintiffs.
Dews proceeded pro se and cannot represent other inmates in this action.
Court considered permissive joinder under Fed. R. Civ. P. 20, 21 and related Ninth Circuit authority.
Significant practical difficulties of multiple pro se co-plaintiffs, such as signing filings and coordinating communications, weighed against joinder.
The court denied Walker and Adderley’s motions to join and directed the clerk to serve this order on them.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Walker and Adderley may join as co-plaintiffs pro se.	Dews cannot represent others; joinder is impracticable due to incarceration.	Courts have discretion to deny permissive joinder when impracticable or burdensome for pro se plaintiffs.	Denied

Simon v. Hartford Life, Inc., 546 F.3d 661 (9th Cir. 2008) (a party may not represent others when pro se)
Fymbo v. State Farm Fire & Casualty Co., 213 F.3d 1320 (10th Cir. 2000) (pro se limitations on representation of others)
Johns v. County of San Diego, 114 F.3d 874 (9th Cir. 1997) (pro se prisoners cannot easily jointly litigate)
C. E. Pope Equity Trust v. United States, 818 F.2d 696 (9th Cir. 1987) (limitations on representation of others in litigation)
Campbell v. Burt, 141 F.3d 927 (9th Cir. 1998) (denial of joinder where co-plaintiffs did not join or desire to join)