Randolph v. Vance
1:19-cv-06377
S.D.N.Y.Jul 8, 2019Background
- Twelve pro se plaintiffs (pretrial detainees at Rikers Island) jointly filed a § 1983 complaint challenging rights in their individual criminal cases and possibly detention conditions.
- The complaint was styled as a "class action" but was procedurally informal and not clear; only Joseph Belmar submitted an IFP application.
- Defendants include Cyrus Vance, the City of New York, and New York State.
- The court analyzed permissive joinder under Fed. R. Civ. P. 20 and the court's authority to sever under Rule 21.
- The court emphasized practical problems of multi-prisoner, pro se litigation: inability of pro se plaintiffs to represent others, Rule 11 signature requirements, and logistical limits on communication in detention leading to delays and piecemeal filings.
- The court severed the action: Belmar remains as sole plaintiff in the original case; the other eleven plaintiffs were each assigned new individual cases and must submit their own IFP/prisoner-authorizations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether multiple detainees may proceed jointly in one § 1983 action | Plaintiffs joined together claiming similar detention/criminal-case harms | Implicitly that claims arise from separate individual cases and management concerns favor severance | Court severed; found claims not from same transactions and joinder impractical |
| Whether joinder should be denied/severed under Fed. R. Civ. P. 21 despite Rule 20 | Plaintiffs implicitly argue joint adjudication is appropriate for similar issues | Defendants and court note prejudice, delay, and inefficiency from multi-prisoner management | Court ordered severance under Rule 21 for fairness and judicial economy |
| Effect of pro se status on joint litigation | Plaintiffs proceed pro se and seek to litigate together | Court: pro se litigants cannot represent others; Rule 11 requires individual signatures; detention hinders coordination | Court held pro se status and logistical barriers justify severance |
| Filing-fee / PLRA implication of joinder | Plaintiffs implicitly sought single-case filing | Court references authority that each prisoner must pay full §1915 fee | Court required each severed plaintiff to file his own IFP and prisoner authorization |
Key Cases Cited
- United States v. Aquavella, 615 F.2d 12 (2d Cir.) (discussing logical relationship test for joinder)
- Wyndham Assocs. v. Bintliff, 398 F.2d 614 (2d Cir.) (Rule 21 permits severance without improper joinder finding)
- Ghaly v. U.S. Dep’t of Agric., 228 F. Supp. 2d 283 (S.D.N.Y.) (district courts have broad discretion on joinder/severance)
- Kehr v. Yamaha Motor Corp., 596 F. Supp. 2d 821 (S.D.N.Y.) (factors for severance: economy, prejudice, witnesses/evidence)
- United States v. Flaherty, 540 F.3d 89 (2d Cir.) (pro se litigants cannot appear for others)
- Iannaccone v. Law, 142 F.3d 553 (2d Cir.) (same principle regarding pro se representation)
- Hagan v. Rogers, 570 F.3d 146 (3d Cir.) (PLRA fee policy and potential consolidation guidance)