Lee v. Cook County, Ill.

Dist. Ct. erred in dismissing without prejudice plaintiffs' Title VII action alleging discrimination in certain promotion decisions where basis of ruling was Dist. Ct.'s belief that contentions of instant three plaintiffs were too disparate to justify joint litigation. Record showed that plaintiff's cases presented common question regarding whether defendant's prison system discriminates against black employees when making promotions, which would have satisfied joinder requirements set forth in Rule 20(a)(1)(B). However, plaintiffs could not proceed on their claims since plaintiffs failed to appeal instant dismissal order and further failed to file amended complaints within applicable limitations period, which continued to run since instant dismissal was without prejudice. Ct. rejected plaintiffs' claim that Dist. Ct.'s extension of time to file new complaints (which plaintiff's counsel still failed to meet) served to extend applicable limitations period. Ct. of Appeals further sanctioned plaintiff's counsel for failing to promptly comply with various rule to show cause orders and for ignoring inquiries from clerk's office, and it also required plaintiff's counsel to send copy of instant opinion to plaintiffs so that they may consider whether to file malpractice lawsuit against counsel.