Williams v. Annucci
- Cathy Seibel
- 7:23-cv-06904
- U.S. District Court · Southern District of New York
- 6
In Byron K. Brown v. Anthony Annucci, Chief Judge Swain severed 30 prisoners’ claims into separate cases without deciding their underlying claims.
Byron K. Brown remains the sole plaintiff in this case. The other 29 incarcerated plaintiffs will receive separate cases and must each address the filing fee or submit an application to proceed without prepaying it. The order does not decide the merits of any plaintiff’s religious-services claim.
What happened
In Byron K. Brown v. Anthony Annucci, 30 incarcerated plaintiffs jointly filed a civil-rights complaint under a federal law allowing claims against state officials. Although they described the case as a class action, most allegations concerned only Byron K. Brown, and only some plaintiffs signed the filings.
The court ordered the claims separated because each plaintiff’s claim involved individual facts and because managing one case among prisoners representing themselves would create practical problems, including delays, missed deadlines, and difficulty sharing information. Brown remains the only plaintiff in this case; the other 29 plaintiffs will receive separate case numbers and must each either pay the $402 filing fee or request permission to proceed without paying it in advance.
Chief Judge Laura Taylor Swain severed the claims under Federal Rule of Civil Procedure 21. The order did not decide whether any plaintiff was entitled to attend religious services or whether the alleged denial violated the law, and it denied permission to appeal without paying fees.
The detailed version
- Williams v. Annucci · No. 7:23-cv-06904
- Cathy Seibel
- Aug. 7, 2023
Background
Byron K. Brown and 29 other incarcerated plaintiffs jointly filed a complaint under 42 U.S.C. § 1983. They alleged that prisoners at Sing Sing Correctional Facility had been denied the opportunity to attend religious services. The complaint described a large group of prisoners affected by an incident on April 14, 2023, but the remaining allegations concerned Brown alone.
The plaintiffs described the complaint as a class action. Brown was the only plaintiff who requested permission to proceed without prepaying the filing fee and submitted a prisoner authorization. The complaint was signed by 20 of the 30 plaintiffs. A jointly filed motion seeking appointment of counsel was signed by 19 plaintiffs, while the supporting memorandum and declaration were signed only by Brown.
Reason for Severance
Federal Rule of Civil Procedure 20 permits multiple plaintiffs to join one lawsuit when their claims arise from the same event or series of events and share a legal or factual question. Rule 21 allows a court to separate claims or parties when doing so will promote fairness, efficiency, and manageable litigation.
The court concluded that the plaintiffs’ claims arose from their individual alleged denials of access to religious services. Each plaintiff would need to provide personal facts about when the denial occurred, how it affected him, and what steps he took to challenge it. The court also found that the practical difficulties of managing a multi-prisoner case—including transfers, release, security restrictions on inmate communications, and the requirement that each unrepresented plaintiff personally sign filings—would hinder effective litigation and judicial efficiency.
Order
The court severed the plaintiffs’ claims from one another under Rule 21. Brown will proceed as the sole plaintiff in this action. The other 29 plaintiffs—Carlos Arriago, Terrence Turner, David Louime, Dennis Antwon, Robert Campbell, Gregory White, Shantee Brooks, Eligidio Lind, Teddy Williams, Hector L. DeJesus, Apolinar Roque, Ricardo Corbin, Terel Overton, Alex Martinez, Deshard Wright, Clayton Scott, Michael A. Crane, Kevin Bussey, Eric Pek, Vaughn Campbell, Ivan T. Ramos, Daniel Jones, Dwayne Reed, Ivan Seabrooks, James Scott, Alen Haymon, Alfonso A. Howard, Stephen Robinson, and Trevor Price—will each receive a new case number. Copies of the complaint, the motion for appointment of counsel, and this order will be placed in each new case.
Each separate case will proceed independently unless the court later treats the cases as related or consolidates them. Each plaintiff will be directed to pay the $402 filing fee or submit an application to proceed without prepaying it and a prisoner authorization. The court also certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying the appellate filing fee.
What the Order Did Not Decide
The order addressed case organization and the propriety of proceeding with multiple plaintiffs in one lawsuit. It did not decide the merits of the alleged denial of religious services, whether any plaintiff’s constitutional rights were violated, or whether the defendants were liable.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.