Hannah v. Rikers Island DOC
- Laura Swain
- 1:25-cv-07075
- U.S. District Court · Southern District of New York
- 7
In White v. Rikers Island DOC, Judge Swain severed the 19 detainees’ claims, keeping White’s case and opening 18 separate actions.
Robert White remains the sole plaintiff in this case. The 18 other named detainees will each have a separate civil action opened, with the complaint and order docketed in each new case. The defendants named in the complaint are Rikers Island DOC and Bob Barker Company, Inc.
What happened
Robert White and 18 other detainees filed one complaint about the mattresses issued at the Otis Bantum Correctional Facility on Rikers Island. The opinion concerns how the claims should be organized, not whether the mattress conditions were unlawful.
The court found that managing one case would be unfair and inefficient because the plaintiffs were representing themselves, could not represent one another, might be transferred or released, and would have limited ability to communicate and coordinate filings.
Judge Swain ordered the claims severed under Rule 21. White remains the sole plaintiff in this case, while each of the other 18 plaintiffs will receive a separate civil action with a new docket number; the court also denied fee-free status for any appeal.
The detailed version
- Hannah v. Rikers Island DOC · No. 1:25-cv-07075
- Laura Swain
- Aug. 26, 2025
Background
Robert White filed a self-represented complaint concerning the mattresses issued to him and 18 other detainees at the Otis Bantum Correctional Facility on Rikers Island. The complaint listed the other detainees as plaintiffs, and they signed it. The order notes that White appeared to have filed the complaint, but that he was the only listed plaintiff who had not signed it; the court said it would separately direct him to submit a signed signature page.
Why the Court Severed the Claims
Federal Rule of Civil Procedure 20 allows multiple plaintiffs to proceed together when their claims arise from the same occurrence or series of occurrences and share a legal or factual question. Rule 21 allows a court to separate claims when doing so is appropriate, including when a combined case would cause prejudice, expense, delay, or management problems.
The court concluded that the practical difficulties of managing a self-represented, multi-detainee case made severance appropriate. Each self-represented plaintiff could appear only for himself or herself and could not act as an attorney for the others. Each plaintiff also would have to personally sign motions and other filings, but transfers or releases could make that difficult. In addition, security concerns would limit the detainees’ ability to discuss strategy, share discovery, and exchange copies of filings. The court determined that proceeding separately would be fairer and more efficient.
Order
The court severed all plaintiffs’ claims under Rule 21. White will proceed as the sole plaintiff in this action. The Clerk of Court must open a separate civil action with a new docket number for each of the other 18 plaintiffs and docket a copy of the complaint and this order in each case. Those cases will proceed independently unless the court later orders otherwise. The court stated that severance did not prevent the cases from later being treated as related or consolidated if appropriate.
The court also certified under 28 U.S.C. § 1915(a)(3) that an appeal from this order would not be taken in good faith and denied fee-free status for purposes of an appeal. The order did not decide the merits of the detainees’ mattress-related claims.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.