Home › Case briefs › Civil Procedure

Mosley v. General Motors Corp.

United States Court of Appeals for the Eighth Circuit · 1974 · Civil Procedure

Civil ProcedurePermissive JoinderRule 20Employment DiscriminationRule 20(a)permissive joindersame transaction or occurrenceseries of transactions or occurrences

Facts

Ten named plaintiffs alleged that General Motors and the union engaged in racially discriminatory employment practices, including discrimination in promotions, terms and conditions of employment, discharge, hiring, retaliation, relief time, and grievance handling. Each plaintiff had filed an EEOC charge before suit, and the EEOC found reasonable cause to believe unlawful employment practices had occurred. The complaint asserted individual claims and class claims against General Motors divisions. The district court concluded the claims were too varied and insufficiently related for joinder and ordered the individual counts severed into separate actions.

Issue

Whether ten plaintiffs alleging they were harmed by the same general policy of racial discrimination by General Motors and the union could join their individual claims in one action under Federal Rule of Civil Procedure 20(a). Also, whether the district court properly postponed ruling on the propriety of the class action allegations pending further discovery.

Rule

Under Rule 20(a), plaintiffs may join in one action if (1) they assert rights to relief arising out of the same transaction, occurrence, or series of transactions or occurrences, and (2) some question of law or fact common to all plaintiffs will arise. "Transaction" is a flexible term defined by logical relationship, so all reasonably related claims may be tried together; absolute identity of events is unnecessary. In employment discrimination cases, an alleged general discriminatory policy can constitute the same series of transactions or occurrences, and the discriminatory character of the defendants' conduct can supply the required common question even if individual plaintiffs experienced different effects.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

Six current and former employees sue Redwood Transit Components, a fictional manufacturer operating in St. Louis and Kansas City, Missouri. One alleges discriminatory refusal to promote, another alleges racially biased discipline, a third alleges retaliatory discharge after complaining, and the others allege discriminatory job assignments; all claim the company maintained a company-wide policy disadvantaging Black employees.

Should the employees likely be permitted to join as plaintiffs in one action under Rule 20(a)?

Explanation. Rule 20(a) requires (1) claims arising out of the same transaction, occurrence, or series of transactions or occurrences, and (2) some common question of law or fact. The majority applied a flexible logical-relationship test and held that an alleged company-wide discriminatory policy can satisfy both requirements, even when plaintiffs suffered different specific harms. The differing effects do not defeat joinder. (Derived from Mosley v. General Motors Corp. (1974).)