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Case 3:22-cv-00134-JAG-MRC Document 26 Filed 12/22/22 Page 4 of 12 PagelD# 133
Il. JOINDER
The Federal Rules of Civil Procedure place limits on a plaintiff's ability to join multiple
defendants in a single pleading. See Fed. R. Civ. P. 20(a). “The ‘transaction or occurrence test’
of [Rule 20] . . . ‘permit[s] all reasonably related claims for relief by or against different parties to
be tried in a single proceeding. Absolute identity of all events is unnecessary.”” Saval v. BL Ltd.,
710 F.2d 1027, 1031 (4th Cir. 1983) (quoting Mosley v. Gen. Motors Corp., 497 F.2d 1330, 1333
(8th Cir. 1974)). “But, Rule 20 does not authorize a plaintiff to add claims ‘against different parties
[that] present[ ] entirely different factual and legal issues.”” Sykes v. Bayer Pharm. Corp., 548 F.
Supp. 2d 208, 218 (E.D. Va. 2008) (alterations in original) (quoting Lovelace v. Lee,
No. 7:03CV00395, 2007 WL 3069660, at *1 (W.D. Va. Oct. 2, 2007)). “And, a court may ‘deny
joinder if it determines that the addition of the party under Rule 20 will not foster the objectives
of [promoting convenience and expediting the resolution of disputes], but will result in prejudice,
expense, or delay.’” Id. (quoting Aleman v. Chugach Support Servs., Inc., 485 F.3d 206, 218 n.5
(4th Cir. 2007)).
In addressing joinder, the Court is mindful that “the impulse is toward entertaining the
broadest possible scope of action consistent with fairness to the parties; joinder of claims, parties
and remedies is strongly encouraged.” United Mine Workers af Am. v. Gibbs, 383 U.S. 715, 724
(1966). This impulse, however, does not provide a plaintiff free license to join multiple defendants
into a single lawsuit where the claims against the defendants are unrelated. See, e.g., George v.
Smith, 507 F.3d 605, 607 (7th Cir. 2007); Coughlin v. Rogers, 130 F.3d 1348, 1350 (9th Cir. 1997).
Thus, “[a] buckshot complaint that would be rejected if filed by a free person—say, a suit
complaining that A defrauded the plaintiff, B defamed him, C punched him, D failed to pay a debt,
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