Gaffney v. Muhammad Ali Enterprises LLC

Background

Michael Gaffney moved under Federal Rule of Civil Procedure 42(a) to consolidate the 2023 action, No. 23-CV-5669, with the related 2018 action, No. 18-CV-8770, and another related action, No. 20-CV-7113. The opinion states that the 20-CV-7113 action had already been consolidated with the 2018 action.

The 2018 action was trial-ready and scheduled for trial in March 2024. The court stated that Gaffney filed the 2023 action as an effort to get around earlier rulings by Judge Daniels denying a late request to add three photos back into the 2018 action. According to the opinion, Gaffney had previously conceded that those photos were not in issue. The 2023 action also asserted claims involving ten new photos that had not been litigated or raised in the 2018 action.

Court’s Analysis

Rule 42(a) gives the court discretion over whether to consolidate cases. The court explained that consolidation may be denied when cases are at substantially different procedural stages and consolidation would delay one case or waste judicial resources. The court found those circumstances present here. It determined that consolidation would cause delay and prejudice and would waste judicial resources.

Rulings

Judge Ona T. Wang denied Gaffney’s motion to consolidate. The court denied Gaffney’s letter motion to seal as moot. The court also stayed the 2023 action pending the outcome of the trial in the 2018 action and directed the Clerk of Court to close the two motion entries.