Streeter v. Vance, 1:19-cv-06380

Twelve pro se detainees at Rikers Island jointly filed a complaint under 42 U.S.C. § 1983 alleging violations arising from their individual criminal cases and detention.
Only one plaintiff, Joseph Belmar, submitted an in forma pauperis (IFP) application and prisoner authorization.
Plaintiffs styled the filing as a class action but the claims stem from separate criminal prosecutions and individual detention circumstances.
The Court analyzed permissive joinder under Fed. R. Civ. P. 20 and the court’s authority to sever under Fed. R. Civ. P. 21.
The Court identified practical obstacles to joint litigation by multiple pro se prisoners (signing requirements, limited ability to confer, security/transitory detention), which would impede fair and efficient case management.
The Court severed the action: Belmar remained as plaintiff in the original case; the other plaintiffs were each assigned new individual docket numbers and must file their own IFP applications and prisoner authorizations.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether multiple plaintiffs may proceed jointly under Rule 20	Plaintiffs joined together alleging similar detention-related claims	Implicitly: defendants/ court argued claims arise from separate prosecutions and lack common transactions	Court assumed claims did not arise from same occurrences and noted distinct individual criminal matters; even if joinder permissible, practical issues weigh against joint case
Whether court should sever the multi-plaintiff action under Rule 21	Plaintiffs sought to litigate jointly	Court argued severance warranted due to prejudice, delay, inefficiency, and management difficulties in pro se multi-prisoner case	Court severed the claims into individual actions under Rule 21
Impact of pro se status on joint litigation (signing, representation)	Plaintiffs proceeded pro se jointly	Court noted pro se litigants cannot represent others; Rule 11 requires each unrepresented party to sign filings; detention/transfers limit collaboration	Court concluded pro se status and operational constraints support severance
Whether each prisoner must pay full filing fee under PLRA if severed	Plaintiffs implicitly sought joint filing to share fee	Court cited authority that PLRA requires each prisoner to pay full fee; shared filing would undermine PLRA deterrent	Court required each severed plaintiff to submit individual IFP application and authorized collection of filing fees; certified appeal not in good faith for IFP appeal purposes

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. 1968) (Rule 21 permits severance even without improper joinder)
Ghaly v. U.S. Dep't of Agric., 228 F. Supp. 2d 283 (S.D.N.Y. 2002) (district courts have broad discretion to decide joinder appropriateness)
Kehr v. Yamaha Motor Corp., 596 F. Supp. 2d 821 (S.D.N.Y. 2008) (factors to consider in severance: judicial economy, prejudice, witnesses/evidence)
Iannaccone v. Law, 142 F.3d 553 (2d Cir. 1998) (pro se litigants may not represent others)
United States v. Flaherty, 540 F.3d 89 (2d Cir. 2008) (reinforcing that nonlawyers cannot appear for others)
Hagan v. Rogers, 570 F.3d 146 (3d Cir. 2009) (PLRA filing fee requires each prisoner to pay full fee; severance/related cases discussion)
Boriboune v. Berge, 391 F.3d 852 (7th Cir. 2004) (PLRA fee analysis requiring full fee per prisoner)
Hubbard v. Haley, 262 F.3d 1194 (11th Cir. 2001) (PLRA fee requirement; policy rationale)
In re Prison Litig. Reform Act, 105 F.3d 1131 (6th Cir. 1997) (contrasting view on fee apportionment among prisoner plaintiffs)
Talley-Bey v. Knebl, 168 F.3d 884 (6th Cir. 1999) (cost apportionment under § 1915(f) analyzed)
Coppedge v. United States, 369 U.S. 438 (1962) (good-faith standard for in forma pauperis appeals)