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United States District Court for the Eastern District of Pennsylvania - 266 F.R.D. 86
Tags: Civil Procedure, Joinder, Permissive Joinder
tl;dr:
This case illustrates the rules for valid permissive joinder, and demonstrates that a court may sever a party if they are joined improperly under FRCP 20.Video Summary
Case Summary
In Cooper v. Fitzgerald (2010), the Eastern District of Pennsylvania U.S. District Court ruled on a case that impacted civil lawsuits involving immigration benefits. The case addressed actions of federal officials who handle immigration applications. The plaintiffs, Karpeh and Kelly Cooper and five others, experienced delays in their U.S. Citizenship and Immigration Services (USCIS) applications. They filed a single complaint against Karen Fitzgerald, the USCIS Philadelphia District Director, and other high-ranking officials, under the Administrative Procedure Act (APA) to force them to act on their applications.
The primary issue was if the plaintiffs correctly joined together under Rule 20(a) of the Federal Rules of Civil Procedure (FRCP). The defendants attempted to separate the Coopers' claims and dismiss the remaining plaintiffs' claims. They argued that the plaintiffs failed to meet the requirements for permissive joinder under Rule 20(a). They said each application was at a different stage and had unique reasons for delay.
The court agreed with the defendants, granting their motion to separate and dismiss. This case highlights the difficulties plaintiffs face when joining together in a single action in federal court, particularly in immigration benefits cases. Furthermore, it shows how courts apply the FRCP to determine if joining is suitable. The court's decision was based on analysis of judicial economy, convenience, and potential prejudice to the plaintiffs. They found that joining would not improve trial convenience or the final determination of disputes and that severance would not harm the plaintiffs, as they could still pursue individual claims.
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The court denied the Defendants' Motion to Sever, as the seven Plaintiffs did not meet the "same transaction" element required for permissive joinder under Rule 20(a). The Plaintiffs' claims were not related to each other, and joinder would not serve judicial economy. The Bausman Declaration confirmed that background checks did not cause delays in the adjudication of the Plaintiffs' immigration benefit applications. Therefore, permissive joinder was not appropriate under Rule 20(a). The Court decided that severance of the Plaintiffs is appropriate under Rule 21.
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