Scott v. County of Kern
1:24-cv-00423
E.D. Cal.Jun 4, 2025Background
- Three related civil actions were filed involving the death of Stephen Ingle while in the custody of Kern County, California.
- The plaintiffs in all actions are either Dianna Scott or the Estate of Stephen Ingle, suing Kern County, Kern County Hospital Authority, and associated defendants.
- The actions center around common factual events and legal claims stemming from the same incident.
- On May 12, 2025, the parties jointly requested consolidation of the cases pursuant to Federal Rule of Civil Procedure 42(a), arguing shared issues of law and fact.
- The parties consented to magistrate judge jurisdiction under 28 U.S.C. § 636(c)(1).
- The court reviewed the stipulation, finding significant overlap in the legal and factual questions among the cases, and granted consolidation for all purposes, designating the first-filed action as the lead case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Consolidation under Rule 42(a) | Cases arise from the same incident; consolidation appropriate | Cases present common questions, no opposition stated | Consolidation granted for all purposes |
| Efficiency of Judicial Resources | Consolidation would reduce duplicative proceedings | Not opposed; agrees proceedings would be streamlined | Court finds consolidation would reduce costs and delays |
| Risk of Inconsistent Adjudication | Consolidation would avoid inconsistent rulings | No argument offered | Court agrees and cites this as a basis for consolidation |
| Magistrate Judge Jurisdiction | Consent to magistrate judge for all further proceedings | Consent to magistrate judge | Magistrate judge jurisdiction granted |
Key Cases Cited
- Garity v. APWU Nat'l Labor Org., 828 F.3d 848 (9th Cir. 2016) (stating a district court's broad discretion in consolidating cases under Rule 42(a))
- Inv’rs Research Co. v. U.S. Dist. Ct. for the Cent. Dist. of Cal., 877 F.2d 777 (9th Cir. 1989) (addressing standards for consolidation under Rule 42(a))
- Huene v. United States, 743 F.2d 703 (9th Cir. 1984) (outlining the factors for weighing consolidation, balancing efficiency with potential inconvenience)
- Single Chip Sys. Corp. v. Intermec IP Corp., 495 F.Supp.2d 1052 (S.D. Cal. 2007) (noting the need to consider savings against possible delays or expense in consolidation)