In Re GEICO General Insurance Company

Background

The parties in Perez v. GEICO Indemnity Company jointly moved to consolidate that case with In re GEICO General Insurance Company. They represented that a proposed global settlement, which was awaiting preliminary approval in the lead case, would resolve the claims brought in Perez if approved.

Legal standard

Federal Rule of Civil Procedure 42(a) permits a court to consolidate cases that involve a common question of law or fact. The court explained that district courts have broad discretion to consolidate cases pending in the same district. In exercising that discretion, the court weighs the time and effort consolidation would save against any inconvenience, delay, or expense it would cause.

Analysis

The court found that the two cases involved common questions of law and fact. It further found that consolidation for purposes of considering the proposed global settlement and, if the settlement were approved, overseeing its implementation would save substantial time and effort. The court did not anticipate significant inconvenience, delay, or additional expense from consolidation.

Ruling and case management

The court granted the parties' request to consolidate the cases for purposes of approving the global settlement and, if approved, overseeing its implementation. Perez v. GEICO Indemnity Company, Case No. 4:20-cv-07436, was consolidated with In re GEICO General Insurance Company, Case No. 4:19-cv-03768. The earlier-filed case was designated the lead case, and the later-filed Perez action was administratively closed. The court directed that all future filings be made only in the lead case under the caption “In re GEICO General Insurance Company.”