Angela Ballanger, et al. v. Missouri State Hospital, et al.

Summary

The United States District Court for the Eastern District of Missouri determined that the claims of four self-represented plaintiffs were improperly joined under Federal Rule of Civil Procedure 20. The court struck Jamie Jones, Jada Davis, and Rudolph Atkins, Sr. from the action, directed the Clerk to open separate cases for them, and required Angela Ballanger to file a signed second amended complaint and a new application to proceed in forma pauperis. The court warned that failure to comply would result in dismissal without prejudice.

Holdings

1. The plaintiffs could not proceed jointly because the record did not show that their claims arose from the same transaction, occurrence, or series of transactions and did not show a common question of law or fact; their claims were factually and procedurally distinct.
2. The court could, on its own motion, sever the improperly joined plaintiffs and claims and require the severed plaintiffs to proceed in separate actions.
3. Self-represented, nonlawyer plaintiffs may not represent the rights, claims, or interests of other individuals or adequately represent a class under Federal Rule of Civil Procedure 23.
4. The joint motion to proceed in forma pauperis was properly denied because the action was proceeding with Ballanger alone and she was required to submit a new motion containing her own financial information.
5. Ballanger was required to file a signed second amended complaint on the court-provided form, and the second amended complaint would supersede the earlier pleadings.

Questions Presented

1. Whether the four plaintiffs satisfied the requirements for permissive joinder under Federal Rule of Civil Procedure 20.
2. Whether the court could sever improperly joined plaintiffs and claims on its own motion under Federal Rule of Civil Procedure 21.
3. Whether self-represented plaintiffs could proceed jointly in a purported class action or represent the rights and claims of other plaintiffs.
4. Whether the joint motion to proceed in forma pauperis should be denied after the action was limited to Ballanger.
5. Whether Ballanger was required to file a signed second amended complaint after the existing amended complaint was incomplete and unsigned.

Disposition

other