## Facts

- Ten Black employees or former employees sued General Motors (Chevrolet and Fisher Body Divisions) and a UAW local, asserting Title VII and 42 U.S.C. § 1981 violations.
- Each plaintiff filed an EEOC charge; the EEOC found reasonable cause and issued right-to-sue notices.
- Plaintiffs filed a twelve-count federal complaint: ten counts asserted individual discrimination claims; two counts asserted class claims.
- The complaint alleged a general pattern or policy of discrimination affecting Black employees (and, in some allegations, female employees), including discrimination in promotions and terms of employment, retaliatory discipline and discharge for protesting discrimination, discriminatory hiring failures, discriminatory discharges, unequal “relief time” practices, and union failures in grievance processing.
- General Motors moved to sever; the district court ordered the first ten counts severed into ten separate actions, reasoning the claims shared only the same employer and lacked common questions of law or fact.
- Plaintiffs pursued an interlocutory appeal limited to whether permissive joinder was proper under Federal Rule of Civil Procedure 20(a).

## Issues

1. Whether the plaintiffs’ claims arose out of the same transaction, occurrence, or series of transactions or occurrences within the meaning of Rule 20(a).
2. Whether any question of law or fact common to all plaintiffs would arise in the action, satisfying Rule 20(a).
3. Whether the district court abused its discretion by severing the joined claims rather than managing any complexity through separate trials or other case-management tools.

## Decision

- The Court of Appeals reversed the severance order and remanded.
- The court held the plaintiffs were properly joined under Rule 20(a) because their claims were “logically related” and linked by allegations of an overarching discriminatory policy by the employer and union.
- The court found multiple common questions of law and fact existed, including whether defendants maintained discriminatory policies and whether challenged practices violated Title VII and § 1981.
- The court concluded the district court abused its discretion by applying an unduly narrow view of Rule 20(a) and by treating “same employer” as the only relevant connection.

## Legal Principles

- Rule 20(a) requires (1) claims arising out of the same transaction, occurrence, or series of transactions or occurrences, and (2) at least one common question of law or fact.
- “Transaction or occurrence” is interpreted broadly; “all logically related events” may constitute a transaction or occurrence, and absolute identity of events is not required.
- Allegations that separate adverse actions stem from a general policy or practice can satisfy the “series of transactions or occurrences” requirement for joinder.
- Even where individualized proof differs across plaintiffs, shared disputes about the legality of an employer’s and union’s policies and practices can supply common questions under Rule 20(a).
- If joinder is proper, trial courts may address prejudice or manageability through Rules 20(b) and 42(b) (including separate trials), rather than severing for lack of joinder.

## Conclusion

The court held that multiple employees alleging distinct adverse actions may proceed together under Rule 20(a) when their claims are logically connected by an alleged common discriminatory policy and share legal and factual questions; the district court’s severance order was reversed as an abuse of discretion.


Mosley v. Gen. Motors Corp., 497 F.2d 1330 (8th Cir. 1974)