Adams v. California Department of Corrections and Rehabilitation

Background

The plaintiffs are 45 presently or formerly incarcerated persons who sued over alleged injuries from a July 20, 2020 incident at Correctional Training Facility Soledad. Three plaintiffs—Shelton Adams, Frederick Brinkley, and Lawrence Brown—were allegedly present during the incident and later contracted COVID-19. Brown also asserted claims on behalf of a proposed class consisting of inmates housed at the facility who contracted COVID-19 between July 20, 2020, and March 15, 2021.

The defendants moved to sever the action. They asked the court to separate Brown from the other plaintiffs and to divide the remaining 44 plaintiffs into 34 separate cases, including cases based on cellmate pairs. They argued that the plaintiffs experienced different uses of force, injuries, witnesses, evidence, and medical issues. The plaintiffs responded that their claims arose from one incident and that the main issue was case management rather than improper joinder.

Legal standard

The court applied Federal Rule of Civil Procedure 20, which permits plaintiffs to join one lawsuit when their claims arise from the same transaction or occurrence and share a question of law or fact. The court also considered whether joinder would be fundamentally fair and whether it would prejudice either side. Under Rule 21, the court may sever a party’s claims, and it has broad discretion to manage the case.

Brown’s claims

The court granted the motion as to Lawrence Brown. It found that Brown was the only proposed class representative and the only plaintiff asserting claims related to contracting COVID-19. The court concluded that separating his COVID-19-based class action from the other 44 plaintiffs’ individualized excessive-force claims would promote efficiency and improve management of the individual claims. The court also found that the plaintiffs had not identified a substantial right that would be prejudiced by severance.

The court therefore severed and dismissed Brown’s claims without prejudice. The action was to continue with the remaining 44 plaintiffs. Brown and the remaining plaintiffs were directed to file separate complaints by March 28, 2025.

The remaining 44 plaintiffs

The court denied the request to sever the remaining 44 plaintiffs into 34 cases for pretrial purposes. It found that their claims arose from the same July 20 incident and involved common questions about what the defendants intended, knew, or should have known. The court acknowledged that managing discovery for 44 individual plaintiffs would require effort, but it found that the defendants had not adequately shown that joint discovery would be impracticable or less efficient than discovery in 34 parallel cases. The court stated that confidentiality concerns could be addressed through a protective order.

The court agreed that trying all 44 individual claims together would likely be infeasible, but it declined to decide the trial structure at that stage. It denied severance for pretrial purposes and said it would revisit severance for trial after discovery and summary-judgment briefing. Discovery taken in one of the two cases would be admissible in both unless the parties agreed otherwise or the court ordered otherwise.

Disposition

The court granted in part and denied in part defendants’ motion to sever. It severed and dismissed all of Lawrence Brown’s claims without prejudice, denied the remainder of the motion, directed the filing of separate complaints, and set a later case-management conference and schedule for briefing on class certification in Brown’s case.