Stevens v. Andrews, et al.

Summary

In this memorandum, the United States District Court for the Middle District of Pennsylvania determined that Dathan Stevens’s pro se 42 U.S.C. § 1983 complaint improperly joined multiple unrelated claims and defendants. The court identified claims involving prison conditions, medical care, excessive force, PREA-related issues, retaliation, and grievances, and gave Stevens the option of voluntary dismissal, severance, or a combination of both. The court warned that severed cases would require separate filing fees and would be subject to mandatory screening.

Holdings

1. Claims against different defendants may be joined only when they arise from the same transaction, occurrence, or series of transactions or occurrences and involve a common question of law or fact. Stevens's claims concerning medical care, excessive force, PREA allegations, and retaliation were unrelated to his conditions-of-confinement claims involving cell searches and dry-cell placements and therefore were not properly joined.
2. The court may require the prisoner plaintiff to choose between voluntarily dismissing unrelated claims, requesting severance into separate lawsuits, or combining those options; the court gave Stevens those choices rather than proceeding with all claims in one action.
3. If Stevens requests full or partial severance, he will be responsible for paying a separate filing fee for each severed case, and each severed case will undergo mandatory screening under the PLRA.

Questions Presented

1. Whether Stevens improperly joined unrelated claims against different defendants in violation of Federal Rule of Civil Procedure 20(a)(2).
2. Whether the court should require voluntary dismissal, severance under Rule 21, or a combination of dismissal and severance for the unrelated claims.
3. Whether the plaintiff would be required to pay separate filing fees for severed prisoner lawsuits under the Prison Litigation Reform Act.

Disposition

other