Taylor v. Gilmore
3:25-cv-00124
N.D. Ind.Apr 14, 2025Background
- John W. Taylor, IV, a pro se prisoner, filed an amended complaint alleging claims against various defendants at two different correctional facilities: Wabash Valley Correctional Facility (WVCF) and Miami Correctional Facility (MCF).
- The complaint included unrelated claims against different individuals at these two separate facilities.
- As required by 28 U.S.C. § 1915A, the court must screen prisoner complaints for frivolousness, failure to state a claim, or claims against immune defendants.
- The court determined that Taylor's complaint improperly joined unrelated claims in a single case, contravening Federal Rules of Civil Procedure 18(a) and 20(a)(2).
- The court gave Taylor the opportunity to file a second amended complaint limited to related claims against appropriate defendants, warning that failure to comply could result in dismissal of unrelated claims.
- Taylor was directed to use the court-approved form and provide specific factual details for his chosen claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether unrelated claims against different defendants at separate facilities can proceed in a single lawsuit | Taylor joined multiple defendants and claims across two facilities in one complaint | Not specifically stated (screening action) | No; unrelated claims must be separated and cannot proceed jointly in one action |
| Propriety of the court dismissing or severing unrelated claims | N/A (Procedural issue raised by court) | N/A (Procedural issue) | The court grants plaintiff the right to choose which related claims to pursue and to refile others separately |
| Plaintiff's right to amend complaint | Taylor, as a pro se litigant, is given a chance to amend his complaint to comply with rules | N/A | Plaintiff may submit a second amended complaint with only related claims |
| Court's power to manage claims under Rules 18, 20, and 21 | N/A | N/A | Court may dismiss or sever unrelated claims if plaintiff does not comply |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se filings are to be liberally construed)
- George v. Smith, 507 F.3d 605 (7th Cir. 2007) (unrelated claims against different defendants belong in different suits)
- Owens v. Evans, 878 F.3d 559 (7th Cir. 2017) (proper joinder rules under Fed. R. Civ. P. 18 and 20)
- Wheeler v. Wexford Health Sources, Inc., 689 F.3d 680 (7th Cir. 2012) (court's options for handling improperly joined claims)
- Katz v. Gerardi, 552 F.3d 558 (7th Cir. 2009) (plaintiff is master of the complaint)
- Luevano v. WalMart Stores, Inc., 722 F.3d 1014 (7th Cir. 2013) (pro se plaintiff's right to amend complaint)
- Loubser v. Thacker, 440 F.3d 439 (7th Cir. 2006) (pro se pleadings and amendment)