Mosley v General Motors Corp

1974

Venue: 8th Cir.

Facts: A pile of different race and sex discrimination claims.

Posture: There are 10 plaintiffs all told, and they're alleging stuff under federal law. District court says they should be severed because they're 10 separate causes of action, because there's no common question of law or fact sufficient to allow joinder under Rule 20.

Issue: Was the district court's order proper?

Holding: Not entirely. Mostly reversed, but there can be separate trials as to individual questions of fact.

Rule: Absolute identity of events is unnecesary: reasonbably related is good enough.

Reasoning: The purpose here is to promote efficiency and uniformity. The rule doesn't require that all questions be common. And these claims do have an underlying theme: discrimination.

Still, it's true that not all issues of fact are common, so once the common questions are resolved, individual trials can be held to address any unique issues.


Dicta: