Ellis et al. v. Werfel

After four prisoners filed a joint lawsuit, the district court erroneously severed it and dismissed three of the prisoners’ complaints based on the false assertion that the Prison Litigation Reform Act (PLRA) categorically bars prisoners from joining together in one lawsuit. The MacArthur Justice Center is fighting to correct that atextual interpretation of the PLRA and ensure prisoners, an already marginalized group, can split a single filing fee, pool their legal knowledge, and share resources – critical abilities to ensure access to the courts. 

Aaron Ellis, Vincent Spinner, Dwayne Young, and one other prisoner jointly filed a lawsuit pro se – meaning the represented themselves – each raising the same straightforward claim about the Internal Revenue Service’s withholding of COVID-19 stimulus payments from prisoners.

Instead of allowing any specific inquiry into whether these plaintiffs should be allowed to proceed jointly with their identical claims, the district court severed Mr. Ellis, Mr. Spinner, and Mr. Young from the original action and dismissed their claims based on the court’s mistaken view that prisoners are categorically barred from joining in one lawsuit together under the PLRA.

The MacArthur Justice Center is representing Mr. Ellis, Mr. Spinner, and Mr. Young on appeal to the U.S. Court of Appeals for the Fourth Circuit, arguing that the U.S. Supreme Court has made it clear that lower courts should not read the PLRA as disrupting the usual operation of the Federal Rules of Civil Procedure without an explicit directive from Congress to do so.

Relevant to this case, Federal Rule 20 says that multiple “persons” may join as plaintiffs in one action, so long as they satisfy two easy-to-meet requirements. And because the PLRA does not say anything at all about joinder, the three plaintiffs should be allowed to proceed in one lawsuit together because they have satisfied the prerequisites for joinder laid out by Federal Rule 20.