Spaeth v. Michigan State University College of Law
845 F. Supp. 2d 48
D.D.C.2012Background
- Spaeth, Missouri resident born 1950, sues six law schools alleging ADEA violations for not offering a tenure-track position after applying for the 2010 AALS Faculty Recruitment Conference.
- Plaintiff’s FAR forms and optional resumes were distributed to AALS members; schools interview selected candidates prior to the Conference.
- Spaeth was interviewed by Missouri and Michigan State; he received no offers in the 2010 cycle; other defendants did hire younger candidates over him.
- Spaeth filed EEOC charges and suit seeking injunction requiring each defendant to offer a tenure-track position, along with declaratory, compensatory, exemplary relief, and fees.
- Defendants moved to dismiss or, in the alternative, sever and transfer; the court granted severance and transfer discussions, ruling severance appropriate and initiating transfer analysis.
- Court severed Spaeth’s claims against Michigan State, Missouri, UC Hastings, and Iowa into four separate Severed Cases and transferred them to each defendant’s home forum under 28 U.S.C. § 1404(a); Maryland and Georgetown remain in the original suit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether joinder of defendants was proper under Rule 20(a). | Spaeth asserts common theory and shared conduct against all defendants. | Defendants contend misjoinder; claims arise from separate, unrelated hiring decisions. | Misjoined; severance appropriate. |
| Whether severance is warranted to avoid prejudice and promote judicial economy. | Severance could cause inconsistent judgments and waste resources; consolidation preferred. | Severance prevents prejudice from intertwined defenses and tainting by circuitous effects. | Severance warranted; avoids prejudice and promotes efficiency. |
| Whether severed cases should be transferred to defendants’ home forums under 28 U.S.C. § 1404(a). | Consolidation in one forum conserves resources and centralizes proceedings. | Home forums better suited to local defendants and local control; convenience and justice favor transfer. | Transfers to Western District of Michigan, Western District of Missouri, Northern District of California, and Southern District of Iowa appropriate. |
| Whether public interest factors, including Eleventh Amendment immunity concerns, support transfer. | Transfer would not affect immunity issues; efficiency concerns prevail. | Eleventh Amendment immunities are better addressed in home forums; local adjudication preferred. | Public interest factors weigh in favor of transfer for the Severed Cases. |
Key Cases Cited
- Davidson v. Dist. of Columbia, 736 F. Supp. 2d 115 (D.D.C. 2010) (two-prong Rule 20(a) analysis for permissive joinder and severance)
- Disparte v. Corporate Exec. Bd., 223 F.R.D. 7 (D.D.C. 2004) (liberal interpretation of Rule 20(a) relatedness and convenience)
- Wynn v. Nat’l Broad. Co., Inc., 234 F. Supp. 2d 1067 (C.D. Cal. 2002) (common issues of law/fact insufficient for joinder; need concerted action)
- Shawnee Tribe v. United States, 298 F. Supp. 2d 21 (D.D.C. 2002) (venue and transfer considerations recognizing local interests)
- Reiffin v. Microsoft Corp., 104 F. Supp. 2d 48 (D.D.C. 2000) (transfer analysis and deference to forum where events occurred)