Joinder is strongly encouraged. However, joinder is only appropriate if both elements of Fed. R. Civ. P. 20(a) are met. Specifically, Rule 20(a) permits the joinder of plaintiffs in a single action if: (1) the plaintiffs have a right to relief arising out of the same transaction, occurrence, or series of transactions or occurrences; and (2) there exists some question of law or fact common to the plaintiffs. Rule 20(a)'s purpose is to promote trial convenience and expedite the final determination of disputes, thereby preventing multiple law suits. The rule is designed to promote judicial economy and reduce inconvenience, delay, and added expense.
Plaintiff applicants filed a single complaint to compel defendant government officials to take action on their individual applications for immigration benefits. Some of the applicants had filed applications to have their spouses declared as immediate relatives, while other applicants had filed applications to adjust status. Contending that plaintiffs claims did not arise out of the same transaction or occurrence and lacked a common question of law or fact, defendants filed a motion to sever the claims of the first-named plaintiffs and dismiss without prejudice the remaining plaintiffs' claims. The court granted defendants' motion to sever and dismissed without prejudice the claims asserted by plaintiffs other than the first-named plaintiffs.
Did the Court err in finding that the plaintiffs were improperly joined?
The court found that plaintiffs were improperly joined because they did not meet the elements of permissive joinder outlined in Fed. R. Civ. P. 20(a). The applicants' claims did not arise out of the same transaction because each application was at a different stage in the adjudication process, none of the applications had been delayed because of name checks or other background checks, and defendants provided specific reasons why each application had been delayed based on the unique factual circumstances surrounding each application. The mere fact that plaintiffs' claims arose under the same general law did not establish a common question of law. Each applicant's claim had to be examined in light of the applicant's individualized circumstances and the unique reasons surrounding any final adjudication delay. The court concluded that severance was appropriate under Fed. R. Civ. P. 21 because judicial economy would not be served by the joinder of plaintiffs and plaintiffs would not be prejudiced by severance.