Joinder and Class Actions under Civil Procedure
Joinder and Class Actions in Civil Procedure
1. Joinder
Joinder refers to the process of including multiple parties or claims in a single lawsuit. Joinder promotes judicial efficiency by allowing related claims or parties to be resolved together rather than in separate lawsuits.
Types of Joinder
a. Permissive Joinder of Parties
Multiple plaintiffs or defendants may join in one action if their claims arise out of the same transaction or occurrence and share common questions of law or fact.
This prevents multiple lawsuits involving the same issues.
b. Compulsory Joinder
Some parties must be joined if they have a significant interest in the case and their absence would prevent the court from fully resolving the controversy.
This ensures fairness and complete resolution.
c. Joinder of Claims
A party may join multiple claims in one lawsuit, even if unrelated, to promote judicial economy.
Important Case Law on Joinder
1. Temple v. Synthes Corp. (1994)
Facts: Plaintiff filed a lawsuit with multiple defendants, some unrelated.
Issue: Whether unrelated claims can be joined in one lawsuit.
Holding: The Supreme Court emphasized that joinder should be proper only if claims arise out of the same transaction or occurrence and have common questions of law or fact.
Significance: Clarified limits on permissive joinder to prevent misuse and undue complexity.
2. Pettway v. American Cast Iron Pipe Co. (1968)
Facts: In a class action, the court considered the propriety of joinder of parties.
Issue: The fairness of joining numerous plaintiffs with diverse claims.
Holding: The court underscored that joinder must respect due process and fairness.
Significance: Important in shaping joinder in complex cases involving many parties.
2. Class Actions
A class action allows one or more plaintiffs to sue on behalf of a larger group (class) with common claims. This mechanism helps efficiently resolve numerous similar claims without clogging courts with multiple individual lawsuits.
Requirements for Class Actions
Numerosity: The class is so large that individual suits would be impractical.
Commonality: Questions of law or fact are common to the class.
Typicality: The claims or defenses of the representative parties are typical of the class.
Adequacy: The representatives will fairly and adequately protect the interests of the class.
Important Case Law on Class Actions
1. Hansberry v. Lee (1940)
Facts: The plaintiff challenged a racially restrictive covenant that had been previously upheld.
Issue: Whether the prior judgment could bind absent class members.
Holding: The Supreme Court held that absent class members must have had proper representation for the judgment to bind them.
Significance: Early recognition of due process rights in class actions and the need for fair representation.
2. Amchem Products, Inc. v. Windsor (1997)
Facts: A proposed class action involving asbestos exposure.
Issue: Whether the class met all certification requirements, including adequacy and commonality.
Holding: The Court held that the differences among class members’ exposures and injuries made certification improper.
Significance: Reinforced rigorous standards for class certification.
3. Wal-Mart Stores, Inc. v. Dukes (2011)
Facts: Employees alleged gender discrimination in pay and promotion.
Issue: Whether the class had sufficient commonality.
Holding: The Court ruled that the claims lacked commonality because of the wide variation in employees’ circumstances.
Significance: Significantly narrowed the scope of class action certification by emphasizing commonality.
Summary
Joinder allows multiple parties or claims to be brought together for efficiency but must meet tests of relatedness and fairness.
Permissive joinder requires common transactional facts; compulsory joinder requires necessary parties be joined.
Class actions let representative parties sue for a large group sharing common claims.
Key requirements include numerosity, commonality, typicality, and adequacy.
Case law like Temple v. Synthes restricts excessive joinder; Hansberry v. Lee and Wal-Mart v. Dukes emphasize fairness and commonality in class actions.
RELATED Blog
0 comments