Martinez v. Annucci

Background

Byron K. Brown and 29 other people incarcerated at Sing Sing Correctional Facility jointly filed a complaint under 42 U.S.C. § 1983. They alleged that more than 200 prisoners had been denied the ability to attend religious services on April 14, 2023. The opinion states that the rest of the allegations concerned only Brown. The plaintiffs described the case as a class action, but the order addressed whether they could continue litigating together.

Twenty of the 30 plaintiffs signed the complaint. Brown was the only plaintiff who asked to proceed without paying the filing fee in advance and submitted a prisoner authorization. Nineteen plaintiffs signed the joint request for appointment of counsel, while the supporting memorandum and declaration were signed only by Brown.

Severance analysis

Federal Rule of Civil Procedure 20 generally permits multiple plaintiffs to join one lawsuit when their claims arise from the same event or related events and share a legal or factual question. Rule 21 permits a court to separate claims even when joinder is not technically improper if keeping the claims together would cause prejudice, expense, delay, or other practical problems.

The court concluded that the plaintiffs’ claims did not arise from one common set of facts. Although the claims were similar because they concerned denial of religious services at Sing Sing, each plaintiff would need to provide individual facts about when the denial occurred, how the denial affected that person, and what steps that person took to challenge it.

The court also found that the practical difficulties of managing a joint lawsuit by people representing themselves supported separation. A person representing themself cannot act as a lawyer for another plaintiff. Each unrepresented plaintiff would also have to personally sign every filing. Transfers, releases, and security restrictions could make it difficult for the plaintiffs to communicate, share discovery, exchange filings, and meet deadlines. The court determined that allowing the case to continue jointly would hinder effective litigation and would not promote efficient use of judicial resources.

Ruling and effect

The court severed the plaintiffs’ claims from one another under Rule 21. Brown will proceed as the sole plaintiff in this case. 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. The complaint, the motion for appointment of counsel, and the order will be placed in each new case.

Each new case will proceed independently unless the court later treats the cases as related or combines them. Each plaintiff will be directed either to pay the $402 filing fee or submit an application to proceed without prepaying fees and a prisoner authorization. The court also certified that an appeal from this order would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal. The order did not reach the merits of the plaintiffs’ religious-services claims.