Thomas Zachary Peters, Antonio Galicia, and Randy McBride v. C. O'Donnell, A. Elgelken, K. Garceau, B. Pierzina, A. Baranowski, A. Acker, S. Kinyon, A. Fennigkoh, D. Zoure, R. Weinman, S. Hall, and J. Hoy

Summary

The United States District Court for the Western District of Wisconsin severed the claims of three pro se prisoner-plaintiffs because their claims arose from distinct transactions, medical circumstances, and legal theories. The court ordered separate cases for Antonio Galicia and Randy McBride, allowed Thomas Peters's claims to proceed under the existing case number, and directed that the claims be screened separately. The court also denied without prejudice motions for preliminary injunctions and denied a motion to amend and join additional plaintiffs.

Holdings

1. The plaintiffs could not maintain their claims together because their allegations arose from multiple unrelated transactions and occurrences, lacked sufficient factual and legal commonality, and would make joint litigation inefficient and unwieldy.
2. The court could and would sever the plaintiffs' claims under Rule 21 and its inherent authority, assigning Galicia and McBride new case numbers while allowing Peters's claims to proceed in the existing case.
3. The motion to amend and join additional parties was denied because the proposed plaintiffs would assert distinct claims arising from disparate facts and would create the same joinder problems present in the original complaint.
4. The plaintiffs failed to establish entitlement to preliminary injunctive relief at that time, so their motions were denied without prejudice.
5. The court could not grant the requested injunctive relief to the extent it was directed at nonparties who would facilitate transfers or medical care.

Questions Presented

1. Whether the plaintiffs' claims satisfied the requirements for permissive joinder under Federal Rule of Civil Procedure 20.
2. Whether the court should sever the plaintiffs' claims and parties under Federal Rule of Civil Procedure 21 and its inherent authority.
3. Whether the plaintiffs should be permitted to amend the complaint to add additional plaintiffs and defendants whose claims were based on unrelated facts.
4. Whether the plaintiffs established entitlement to preliminary injunctive relief.
5. Whether injunctive relief could be directed at nonparties who would facilitate transfers or medical care.

Disposition

other