Madera v. Rikers Island DOC

Background

Robert White filed a pro se complaint challenging the conditions of confinement relating to mattresses issued at the Otis Bantum Correctional Facility on Rikers Island. The complaint also listed 18 other detainees as plaintiffs, and each of those 18 individuals signed the complaint. The opinion notes that White appeared to be the person who filed the complaint, but that he could not represent the other plaintiffs. It also notes that White was the only listed plaintiff who had filed an application to proceed without paying the filing fee and a prisoner authorization, and that he appeared to be the only listed plaintiff who had not signed the complaint. The court said it would direct White, in a separate order, to submit a signed signature page.

Reason for Severance

Federal Rule of Civil Procedure 20 permits multiple plaintiffs to join one case when their claims arise from the same occurrence or related occurrences and involve a common legal or factual question. Rule 21 allows a court to separate claims even without finding that joinder was improper. The court concluded that separating the claims would promote efficient case management and fairness.

The court identified several practical problems with allowing the 19 detainees to proceed together. Because they were representing themselves, none could act as an attorney for the others. Each plaintiff would also have to personally sign motions and other court papers. Transfers or releases from the pretrial detention facility could prevent some plaintiffs from signing future filings. In addition, security restrictions would limit the detainees’ ability to discuss strategy, share discovery, or provide one another with copies of court papers, creating risks of piecemeal filings, delays, and missed deadlines.

Order

The court severed the claims of all plaintiffs under Rule 21. Robert White will remain the sole plaintiff in this action. The Clerk of Court was directed to open a separate civil action, with a new docket number, for each of the other 18 plaintiffs and to docket a copy of the complaint and this order in each new case. The new cases will proceed independently, and the plaintiffs will not be treated as co-plaintiffs unless the court later orders otherwise.

The order did not decide whether the cases could later be treated as related or consolidated. The court also directed the other plaintiffs to submit signed applications to proceed without paying the filing fee and prisoner authorizations once their new cases were opened.

Finally, the court certified under 28 U.S.C. § 1915(a)(3) that any appeal from the order would not be taken in good faith and denied permission to appeal without paying the filing fee. The order was signed by Chief United States District Judge Laura Taylor Swain on August 26, 2025.