## Facts

- Johnny Marino was the Sheriff of St. Charles Parish, Louisiana.
- Seven deputies sued Marino after their commissions as deputies were not renewed when he continued in office following his re-election.
- All seven plaintiffs asserted First Amendment violations, but the asserted factual bases differed among them.
- Several plaintiffs alleged retaliation because they did not support, or were perceived as not supporting, Marino’s re-election effort (including allegations of perceived support for an opponent).
- Other plaintiffs alleged retaliation tied to their law-enforcement actions against Marino’s political supporters.
- Some plaintiffs alleged retaliation based on their speech at public meetings.
- One plaintiff, Claudette Wilson, alleged First Amendment violations connected to events surrounding her workers’ compensation claim.
- In addition to the First Amendment claims, several plaintiffs (including Wilson) asserted claims of racial discrimination.
- Marino moved to sever the plaintiffs’ claims as misjoined under Federal Rule of Civil Procedure 20(a), or alternatively requested separate trials under Rule 42(b), arguing the claims were too individualized and that trying them together could confuse the jury and waste time.

## Issues

1. Whether the seven deputies were properly joined under Fed. R. Civ. P. 20(a) because their claims arose out of the same transaction, occurrence, or series of transactions or occurrences and included at least one common question of law or fact.
2. Whether, even if joinder was proper, the court should order separate trials under Fed. R. Civ. P. 42(b) for convenience, to avoid prejudice, or to speed resolution and reduce wasted effort.

## Decision

- The court denied Marino’s motion to sever under Rule 20(a).
- The court held the plaintiffs’ claims could be tried together because they arose from a related series of employment decisions by the same sheriff concerning the non-renewal of commissions, and the case presented overlapping legal and factual questions (including alleged First Amendment retaliation).
- The court rejected the argument that differences in each plaintiff’s factual narrative (including Wilson’s workers’ compensation-related allegations and the presence of race-discrimination claims by some plaintiffs) required severance.
- The court also denied Marino’s alternative request for separate trials under Rule 42(b).
- The court concluded that multiple separate trials would likely repeat evidence and consume more court time, and that any risk of jury confusion could be handled through trial organization and jury instructions rather than splitting the case.

## Legal Principles

- Rule 20(a) is applied liberally; plaintiffs may join in one action when their claims arise from the same transaction or occurrence, or a related series of transactions or occurrences, and there is at least one common question of law or fact.
- Claims need not be identical to satisfy Rule 20(a); differences in factual details do not defeat joinder when the claims are logically related and involve overlapping proof and legal standards.
- A single defendant’s related employment decisions affecting multiple employees within the same general time period can constitute a “series of transactions or occurrences” for Rule 20(a) purposes.
- Under Rule 42(b), separate trials are discretionary and may be ordered only when separation would materially aid convenience, reduce unfair prejudice, or improve the speed and efficiency of adjudication.
- Generalized concerns about jury confusion, without a concrete showing of unfair prejudice that cannot be handled through instructions and trial management, are not enough to require separate trials.

## Conclusion

In *Guedry v. Marino*, the court kept seven deputies’ civil-rights claims in one case, holding that their challenges to the sheriff’s non-renewal decisions were sufficiently related for permissive joinder under Rule 20(a) and that separate trials under Rule 42(b) were not justified where overlap in issues and proof outweighed speculative concerns about jury confusion.


Guedry v. Marino, 164 F.R.D. 181 (1995)