Miles v. Schiller

Background

Gordon Miles had two pending lawsuits. In Miles v. Schiller, he alleged that another client at the MSOP facility sexually assaulted him, that defendants prevented him from reporting the alleged assault to police, and that he was moved to a more restrictive living unit without due process. In Miles v. Hartley, he alleged a different sexual assault, that defendants again prevented him from reporting it to police, and that defendants failed to provide appropriate treatment afterward.

The cases involved many of the same defendants, but each also included unique defendants. Both cases had pending motions to dismiss from defendants who worked for MSOP and pending motions for judgment on the pleadings from defendants who worked for the Moose Lake Police Department. The court had also recommended dismissing all claims in Hartley, and that recommendation was awaiting district-court review. A third case that Miles sought to combine had already been dismissed in full.

Legal standard

Federal Rule of Civil Procedure 42(a) allows a court to combine cases that share a common legal or factual question. The party requesting consolidation must show that combining the cases would promote judicial convenience and efficiency. Courts may consider the risk of prejudice or confusion, the risk of inconsistent decisions, the burden on the parties and witnesses, the effect on court resources, the time needed to resolve the cases, and the relative expense of one trial versus multiple trials.

Court’s reasoning

The court held that Miles had not met his burden for two reasons. First, it found the request premature because motions to dismiss were pending in both cases, including a case with a pending recommendation to dismiss all claims.

Second, the court found that consolidation would not promote judicial efficiency. Although the cases shared some legal issues, their factual issues were largely separate because each arose from an alleged incident unconnected to the other. The cases also included different defendants, including John Doe defendants who might or might not be the same people.

Disposition

The court denied Miles’s motions to consolidate Miles v. Hartley and Miles v. Schiller. The order did not decide the underlying allegations in either lawsuit.