Alexander v. Fulton County

207 F.3d 1303

 

RULE:

A party seeking joinder of claimants under Fed. R. Civ. P. 20 must establish two prerequisites: 1) a right to relief arising out of the same transaction or occurrence, or series of transactions or occurrences, and 2) some question of law or fact common to all persons seeking to be joined. Fed. R. Civ. P. 20(a).

FACTS:

Plaintiffs, current and former employees, sued defendants, county sheriff and sheriff's department, alleging that defendants maintained a "policy or custom" of racial discrimination in employment decisions under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq. and 42 U.S.C.S. §1983. The jury returned a verdict in favor of plaintiffs, finding that defendant county maintained a policy or custom of discrimination against white employees and that defendant sheriff intentionally discriminated against white employees.

ISSUE:

Can multiple plaintiffs join in one action if they claim to have suffered the same systematic discrimination?

ANSWER:

Yes.

CONCLUSION:

Given the common core of allegations, the substantial overlap of the particular claims, and the logical interconnection of several of the different forms the alleged discrimination took, joinder was permissible.

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