Spaeth v. Michigan State University College of Law
2012 U.S. Dist. LEXIS 20742, 81 Fed. R. Serv. 3d 1371, 845 F. Supp. 2d 48 (2012)
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Rule of Law:
Multiple defendants who independently engage in similar but unconcerted acts cannot be joined in a single lawsuit under Federal Rule of Civil Procedure 20(a). Such claims must be severed and transferred to venues where each individual claim arose, as independent decisions do not constitute a single 'transaction or occurrence.'
Facts:
- Nicholas Spaeth, born in 1950, was a citizen and resident of Missouri.
- In 2010, Spaeth applied for tenure-track teaching positions at numerous law schools, including Michigan State, Missouri, UC Hastings, and Iowa.
- He submitted his applications through the American Association of Law Schools (AALS) Faculty Appointments Register as part of a single, nationwide hiring cycle.
- The AALS process culminated in a Faculty Recruitment Conference held in Washington, D.C.
- Each defendant law school independently reviewed Spaeth's application and made its own decision regarding his candidacy on their respective campuses.
- Michigan State, UC Hastings, and Iowa decided not to interview Spaeth.
- The University of Missouri interviewed Spaeth at the AALS conference but ultimately did not offer him a position.
- Each defendant law school hired other, younger candidates who Spaeth alleged were less qualified.
Procedural Posture:
- Nicholas Spaeth filed Charges of Discrimination with the Equal Employment Opportunity Commission (EEOC) against each defendant law school.
- After receiving Notices of Right to Sue from the EEOC, Spaeth filed a single lawsuit against Michigan State University College of Law, the University of Missouri School of Law, and several other law schools in the U.S. District Court for the District of Columbia, a federal trial court.
- The defendants filed motions to dismiss for failure to state a claim, or in the alternative, to sever the claims and transfer venue to their respective home districts.
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Issue:
Does Federal Rule of Civil Procedure 20(a) permit a plaintiff to join multiple, unrelated employers in a single age discrimination lawsuit where each employer independently decided not to hire the plaintiff after he applied to them through a common recruitment process?
Opinions:
Majority - Huvelle, J.
No. Federal Rule of Civil Procedure 20(a) does not permit joining multiple, unrelated employers in a single lawsuit when their alleged discriminatory actions were independent of one another. To satisfy the 'same transaction, occurrence, or series of transactions or occurrences' prong of Rule 20(a), a plaintiff must allege some form of concerted action or shared policy among the defendants. Merely engaging in similar types of behavior or participating in the same industry-wide hiring process is insufficient. Here, Spaeth alleged that each law school made an independent hiring decision, so the claims are not logically related in the manner required by the rule. Furthermore, the claims do not share a common question of fact because the decision-makers, hiring criteria, and specific circumstances at each school were unique. Because the defendants were improperly joined, the claims against them must be severed under Rule 21. Following severance, a transfer of venue analysis under 28 U.S.C. § 1404(a) demonstrates that each individual case should be transferred to the defendant's home district, as that is where the hiring decisions were made, the witnesses and evidence are located, and the local interest in the controversy is strongest.
Analysis:
This decision clarifies the limits of permissive joinder in employment discrimination cases involving multiple, unrelated employers. It establishes that a centralized application process, like the AALS register, is insufficient to transform independent hiring decisions into a 'single series of transactions' for joinder purposes. The ruling reinforces the requirement of alleging 'concerted action' to sue multiple defendants in one action, thereby preventing plaintiffs from bundling disparate claims against different companies simply because they operate in the same industry and allegedly committed the same type of legal violation. This has a significant practical impact, often forcing plaintiffs to file separate lawsuits in different jurisdictions, which increases litigation costs and complexity for the plaintiff.
