Riley et al v. Klahr et al

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
CARMEN RILEY, et al.,
Plaintiffs,
v.
PRIMECARE MEDICAL, INC., et al.,
Defendants.
No. 4:20-CV-00325
(Chief Judge Brann)
MEMORANDUM OPINION
FEBRUARY 20, 2026
This matter arises out of the tragic death of Ty’rique Riley (“Riley”) while in
custody of officials in Dauphin County. Riley was initially arrested and placed in the
custody of several defendants associated with the Dauphin County Booking Center
(“Booking Defendants”) where he was allegedly subjected to excessive force before
being transferred to the custody of other defendants who are associated with the
Dauphin County Prison (“Prison Defendants”) where he was again allegedly
subjected 	to 	excessive 	force. 1 During 	this 	time, 	PrimeCare 	Medical, 	Inc.
(“PrimeCare”), allegedly provided negligent treatment for Riley, which exacerbated
his mental health issues in the days before his death while in the custody of Prison
Defendants.
1 	Booking Defendants and Prison Defendants are collectively referred to as “Correctional
Defendants.”
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All of the defendants now move to sever the claims against them from the
claims against the other defendants, effectively requesting three separate trials in this
matter. However, because all of the claims arise from the same nucleus of facts, and
because the facts relevant to each individual defendant are necessary to provide
adequate context for the claims against the other defendants, the motions will be
denied.
I. 	BACKGROUND
In February 2020, Carmen Riley, as administrator of Riley’s estate, filed a
complaint in this matter, which was subsequently twice amended.2 The second
amended complaint, filed in April 2021, raised claims for conspiracy to commit
excessive force, conspiracy to deny medical care, two counts of excessive force, two
counts of failure to intervene, failure to train and supervise, failure to provide
medical care, medical negligence, intentional infliction of emotional distress,
assault, battery, wrongful death, and a survival action. 3
Several motions for summary judgment were filed, and a Report and
Recommendation issued.4 This Court thereafter adopt in part and rejected in part the
Report and Recommendation and granted in part and denied in part the motions for
summary judgment.5 Specifically, this Court found that the evidence was sufficient
2 	Docs. 1, 16, 64.
3 	Doc. 64.
4 	Docs. 157, 160, 164, 173, 247.
5 	Docs. 272, 273.
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for Plaintiffs’ claim for: excessive force as against Robert Ingersoll, Cameron
Weaver, Greg Mendenhall, and Scott Lewis; failure to intervene as to Weaver,
Mendenhall, Delta Bauer, Scott Grieb, Andrew Klahr, Keith Biter, Steve Singleton,
Keith Hoffman, and Matthew Danner; assault with respect to Ingersoll, Weaver,
Mendenhall, and Lewis; battery as against Ingersoll, Weaver, Mendenhall, and
Lewis; wrongful death with regard to Klahr, Lewis, Biter, Singleton, Hoffman, and
Danner; and survivor act as to Ingersoll, Weaver, Mendenhall, Bauer, Grieb, Klahr,
Lewis, Biter, Singleton, Hoffman, and Danner. 6
This Court granted judgment in favor of PrimeCare, concluding that Plaintiffs
had failed to sustain a claim for medical negligence, wrongful death and survival, or
punitive damages. 7 As to the claim for medical negligence, the Court determined
that, although there were many alleged deficiencies in PrimeCare’s treatment of
Riley, these deficiencies has “nothing to do with death by excessive force.”8 Because
any deficiency in mental health treatment was not the proximate cause of Riley’s
death, PrimeCare could not be held liable in any manner for Riley’s death.9
Plaintiffs thereafter filed a motion for reconsideration as to the dismissal of
claims against PrimeCare, arguing that their medical negligence claim should
6 	Doc. 273.
7 	Doc. 272 at 85-95.
8 	Id. at 90.
9 	Id. at 91-95.
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survive. 10 This 	Court 	granted 	reconsideration, 	concluding 	that 	Plaintiffs 	had
proffered an expert report that discussed multiple instances where PrimeCare staff
failed to adequately assess Riley and opined that each failure “caused Riley’s decline
in mental functioning to continue.”11 However, as to any claim relating to Riley’s
death, this Court stood “on its prior reasoning regarding the lack of expert evidence
tying PrimeCare’s medical negligence to Riley’s death” since Plaintiffs
failed to provide any expert evidence at all tying Riley’s death to
PrimeCare’s medical negligence. Any injury caused by the tortuously
excessive force deployed by prison guards was not proximately caused
by preceding medical negligence, even if that medical negligence was
a but-for cause of the mental deterioration which in turn caused the
physical confrontation.12
With that ruling, claims of excessive force under 42 U.S.C. § 1983 and related
issues proceeded as against Correctional Defendants, while state law claims of
medical negligence and survival action proceeded as to PrimeCare. Now pending
before the Court is PrimeCare’s motion to dismiss or, in the alternative, to sever,
together with a motion to sever filed by the Correctional Defendants.13
As to PrimeCare’s motion to dismiss, it argues that this Court should decline
to exercise supplemental jurisdiction and dismiss the claims against it without
prejudice because the Court has dismissed all claims over which it had original
10 	Doc. 274.
11 	Doc. 286 at 6; see id. at 5-6.
12 	Id. at 9.
13 	Docs. 288, 290.
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jurisdiction, and there is no connection between the remaining claims against
PrimeCare and those against Correctional Defendants.14 Alternatively, PrimeCare
contends that claims against it should be severed, as the issues to be tried are
significantly different and will require different evidence, Plaintiffs will not be
prejudiced by severance, and PrimeCare would be prejudiced by the failure to
sever. 15
Correctional Defendants move to sever claims between Booking Defendants
and Prison Defendants on the grounds that the claims against them share no common
factual 	or 	legal 	issues 	and 	arise 	from 	different 	controversies. 16 Moreover,
Correctional Defendants assert that the issues underlying the claims against them are
different and require different proof, Plaintiffs will suffer no prejudice from
severance, and the Correctional Defendants will be prejudiced by the failure to sever
the counts. 17
Plaintiffs respond that PrimeCare’s motion to dismiss should be denied
because 	there 	remain 	some 	claims 	over 	which 	the 	Court 	possesses 	original
jurisdiction and, in any event, considerations of judicial economy, convenience, and
fairness militate in favor of retaining jurisdiction.18 And in contrast to PrimeCare’s
14 	Doc. 292 at 5-8.
15 	Id. at 9-14.
16 	Doc. 291 at 13-17
17 	Id. at 18-26.
18 	Doc. 294 at 7-13.
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contention, Plaintiffs assert that the claims should not be severed because they have
substantial 	factual 	overlap 	and 	overlap 	in 	evidence, 	severance 	would 	cause
substantial 	prejudice 	to 	Plaintiffs, 	denial 	of 	severance 	would 	not 	prejudice
PrimeCare, and severance would waste significant judicial resources. 19 Plaintiffs
offer similar arguments in opposition to Correctional Defendants’ motion to sever.20
The defendants have filed reply briefs to the pending motions,21 rendering
those motions ripe for disposition. For the following reasons, the motions will be
denied.
II. 	DISCUSSION
A. 	Motion to Dismiss
The Court turns first to PrimeCare’s argument that this Court should decline
to exercise supplemental jurisdiction over the remaining state law claims against
PrimeCare. 	Federal 	law 	provides 	that, 	when 	district 	courts 	possess 	original
jurisdiction over a claim, it “shall have supplemental jurisdiction over all other
claims that are so related to claims in the action within such original jurisdiction that
they form part of the same case or controversy under Article III of the United States
Constitution.”22 However, “district courts may decline to exercise supplemental
19 	Id. at 13-20.
20 	See Doc. 293.
21 	Docs. 295, 296.
22 	28 U.S.C. § 1367(a).
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jurisdiction over a claim” in four prescribed circumstances, only one of which is at
issue here. 23
PrimeCare asserts only that dismissal is appropriate because the Court “has
dismissed all claims over which it has original jurisdiction.”24 The United States
Court of Appeals for the Third Circuit has held that “where the claim over which the
district court has original jurisdiction is dismissed before trial, the district court must
decline to decide the pendent state claims unless considerations of judicial economy,
convenience, and fairness to the parties provide an affirmative justification for doing
so.”25
It is true, as PrimeCare asserts, that this Court dismissed all claims against
PrimeCare over which it had original jurisdiction, leaving only state law claims
pending against PrimeCare.26 It is equally true, as Plaintiffs point out, that claims
remain 	against 	Correctional 	Defendants 	that 	are 	based 	upon 	federal 	law—
specifically, 42 U.S.C. § 1983.27 This raises a question that does not appear to have
yet been resolved by the Third Circuit: whether 28 U.S.C. § 1367(c)(3) is triggered
23 	Id. § (c).
24 	Id. § (c)(3). See Doc. 292 at 6-8. Although PrimeCare references 28 U.S.C. § 1367(c)(4), which
provides that courts may decline to exercise supplemental jurisdiction if, “in exceptional
circumstances, there are other compelling reasons for declining jurisdiction,” PrimeCare does
not develop this argument in any way. In any event, there are no compelling circumstances
apparent to the Court that would justify declining jurisdiction under Subsection 1367(c)(4).
25 	Hedges v. Musco, 204 F.3d 109, 123 (3d Cir. 2000) (internal quotation marks omitted).
26 	Doc. 292 at 7.
27 	Doc. 294 at 7.
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when all federal claims are dismissed against the relevant defendant, or only when
all federal claims are dismissed as against all defendants within a case.
The plain language of the statute demonstrates that Subsection (c)(3) applies
only when all federal claims as to all defendants have been dismissed, as the statute
speaks to “all claims,” not “all claims against a defendant.” 28 Numerous courts have
reached such a conclusion.
By way of example, in Hansen v. Board of Trustees of Hamilton Southeastern
School Corporation, the United States Court of Appeals for the Seventh Circuit
confronted a situation where the “district court’s original jurisdiction derived from
claims against both Alano and HSSC under 42 U.S.C. § 1983 and Title IX. After
granting summary judgment on the Title IX claim, the district court retained original
jurisdiction over the claims against Alano, including the claim under 42 U.S.C.
§ 1983.”29 Although the district court had dismissed all federal claims against HSSC,
“the district court had not dismissed all federal claims over which it had original
jurisdiction” since there was a pending federal claim against Alano.30 Consequently,
“the district court’s discretion to relinquish jurisdiction under § 1367(c)(3) was
never triggered, because the court did not dismiss ‘all claims over which it has
original jurisdiction.’” 31
28 	28 U.S.C. § 1367(c)(3).
29 	551 F.3d 599, 607-08 (7th Cir. 2008).
30 	Id. at 607.
31 	Id. at 608.
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The United States District Court for the District of Kansas also directly
considered whether § 1367(c)(3) applies “only after the court has dismissed all
claims over which it had original jurisdiction against all defendants or, instead, if
the court may apply § 1367(c)(3) . . . once it has dismissed all claims over which the
court had original jurisdiction against that particular defendant.”32 That court first
noted that “Moore’s Federal Practice takes the approach that § 1367(c)(3) ‘refers to
all claims in the case, not just those claims asserted against a particular defendant.’”33
It then determined that:
This interpretation of § 1367(c)(3)—requiring dismissal of all original
jurisdiction claims against all defendants before declining supplemental
jurisdiction—makes sense when viewed against the history of § 1367.
In 	1990, 	Congress 	enacted 	§ 	1367 	to 	expand 	district 	courts’
supplemental jurisdiction to include jurisdiction over additional claims
involving other parties, in addition to supplemental jurisdiction over
other claims between the same parties where the court had original
jurisdiction over at least one of their claims. 34
That, combined with the fact that § 1367 was enacted with the explicit goal of
extending supplemental jurisdiction to cover “claims involving different parties,” 35
convinced the court that § 1367(c)(3) applies only when a court dismisses “all claims
over which it has original jurisdiction against all parties (i.e., all original jurisdiction
32 	Gorenc v. Proverbs, 462 F. Supp. 3d 1137, 1157 (D. Kan. 2020).
33 	Id. (quoting 15A James Wm. Moore, et al., Moore's Federal Practice § 106.66[1] (3d ed. &
Supp. 2020)).
34 	Id. at 1158.
35 	Id. (quoting Exxon Mobil Corp. v. Allapattah Servs., Inc., 545 U.S. 546, 558 (2005)).
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claims in the case—and not just the federal claims against the particular defendants
the supplemental claims are asserted against).”36
As PrimeCare acknowledges, federal claims remain pending against the other
remaining defendants in this matter.37 Because federal claims still exist, § 1367(c)(3)
is not triggered, and it remains appropriate for this Court to exercise supplemental
jurisdiction over the remaining state law claims against PrimeCare. The motion to
dismiss will therefore be denied.
B. 	Motions to Sever
The Federal Rules of Civil Procedure permit district courts to “sever any claim
against a party.”38 “Severance is appropriate when the claims are ‘discrete and
separate,’ each capable of resolution without dependence or effect on the other.” 39
The decision to sever claims is vested within the discretion of the district court. 40
Although the Third Circuit has not set forth considerations for determining
when severance is appropriate, within the circuit it is widely accepted that courts
should consider three factors: “(1) whether the issues sought to be severed are
significantly different from one another and would require distinct evidentiary proof;
36 	Id.
37 	Doc 296 at 2.
38 	Fed. R. Civ. P. 21.
39 	Henderson v. Mahally, 639 F. Supp. 3d 481, 486 (M.D. Pa. 2022) (quoting Gaffney v.
Riverboat Servs. of Ind., Inc., 451 F.3d 424, 442 (7th Cir. 2006)).
40 	Thompson v. Ferguson, 849 F. App’x 33, 35 (3d Cir. 2021).
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(2) whether severance would promote judicial economy; and (3) whether either party
will be unduly prejudiced by severance or its absence.” 41
1. 	PrimeCare’s Motion
Turning first to PrimeCare’s motion to sever, the Court finds that the relevant
factors weigh against granting the motion. First, although the legal issues presented
are different as between PrimeCare and Correctional Defendants, the evidence that
must be presented would overlap to a significant extent.
Plaintiffs’ primary claim against PrimeCare is that of medical negligence
which, as this Court has previously observed, requires Plaintiffs to “establish a duty
owed by the physician to the patient, a breach of that duty by the physician, that the
breach was the proximate cause of the harm suffered and the damages were a direct
result of the harm.” 42 In contrast, Plaintiffs’ claims against Correctional Defendants
primarily rest on allegations of excessive force, which requires proof that an
objectively reasonable individual would understand that the force employed was
unreasonable, using six non-exhaustive factors, including:
[1] the relationship between the need for the use of force and the amount
of force used; [2] the extent of the plaintiff’s injury; [3] any effort made
by the officer to temper or to limit the amount of force; [4] the severity
of the security problem at issue; [5] the threat reasonably perceived by
the officer; and [6] whether the plaintiff was actively resisting.43
41 	Henderson, 639 F. Supp. 3d at 486-87.
42 	Doc. 272 at 88.
43 	Id. at 16.
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There is no doubt that these legal considerations offer little, if any, overlap.
This is especially so because this Court has already concluded as a matter of law that
any medical negligence is wholly unconnected with any injuries caused by alleged
excessive force. 44 While those claims are legally distinct, however, they will not
require entirely distinct proof and testimony.
Here, all claims arise out of a series of interrelated occurrences; most
incidents, although facially separate from the others, are necessary for a fulsome
understanding of the events that form the central part of each claim against each
defendant. Understanding the uses of force deployed on Riley and how that impacted
Riley’s mental health is critical for the jury to understand whether PrimeCare was
negligent in treating Riley. Conversely, Riley’s deteriorating mental health—and
what the Correctional Defendants knew of that deterioration—may be relevant to
whether the force used was reasonable under the circumstances. The same video and
documentary evidence must also be presented for all claims.
Beyond how these facts would be legally relevant to each claim, they would
be necessary to complete the picture for the jury in consideration of any of the
claims. The jury would necessarily need to know the facts underlying Riley’s initial
detention and transfers between facilities or the circumstances of Riley’s treatment
would be entirely unintelligible to the jurors. In short, the jury would need all of the
44 	Doc. 286 at 9.
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facts of Riley’s detention to understand why mental health treatment was necessary,
why it was deteriorating, and why PrimeCare allegedly should have known that this
was occurring. The first factor therefore weighs against severing the claims.
As to the second factor, the Court concludes that severance would not promote
judicial economy. In a slightly different context the United States Court of Appeals
for the Seventh Circuit has explained that “[e]valuating considerations of judicial
efficiency and duplication of judicial effort is not just a matter of toting up months
or motions or the page counts of judicial orders.” 45 “Rather, concerns about judicial
economy have their greatest force when significant federal judicial resources have
already been expended to decide the state claims, or when there is no doubt about
how those claims should be decided” rather than when resources are expended over,
for example, discovery disputes. 46
In this case, significant resources were expended in resolving the merits of the
underlying state law claims. This included the production of a 151-page Report and
Recommendation related to the motions for summary judgment, a 103-page
Memorandum Opinion assessing the Report and Recommendation, as well as a
relatively short 15-page Memorandum Opinion addressing Plaintiffs’ motion for
reconsideration 	as 	to 	the 	claims 	against 	PrimeCare. 47 Having 	been 	involved
45 	RWJ Mgmt. Co. v. BP Prods. N. Am., Inc., 672 F.3d 476, 481 (7th Cir. 2012).
46 	Id.
47 	Docs. 247, 272, 286.
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extensively in the merits of this case, the Court is intimately familiar with both the
underlying law and facts that are important here. More importantly, presenting these
matters in one trial would streamline the proceedings against all defendants;
Plaintiffs would not be forced to present repetitive and overlapping evidence in three
separate 	trials. 	Considerations 	of 	judicial 	economy 	therefore 	militate 	against
severance. 48
Finally, with respect to the third factor, there would be little prejudice to
PrimeCare in denying its motion, but certain prejudice to Plaintiffs in granting the
motion. PrimeCare argues that it would be prejudiced by the introduction of
evidence related to the use of excessive force and Riley’s death, and no instruction
would cure the prejudice or eliminate confusion to the jury.49 But as explained
earlier, much of that evidence would need to be presented in any event in order to
give the jury a holistic view of the situation in which Riley was placed and why the
need for mental health treatment was allegedly so acute. Of course, a limiting
instruction—if requested—would be given to the jury regarding such evidence.
Similarly, to the extent that the evidence presented in a joint trial would go beyond
what evidence is strictly necessary to understand the claims against PrimeCare, the
48 	Cf. Borough of W. Mifflin v. Lancaster, 45 F.3d 780, 789 (3d Cir. 1995) (finding that, where
“there is a common nucleus of operative facts,” issues of “judicial economy, convenience,
fairness to the parties, and comity are better served by” retaining supplemental jurisdiction)
(brackets and internal quotation marks omitted)).
49 	Doc. 292 at 12-13.
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Court sees no reason why any potential prejudice could not be cured by proper
limiting instructions. Nor does the Court think the jury incapable of deciding
multiple claims against varying defendants without growing confused—a task that
juries routinely perform without issue.
In contrast, Plaintiffs would, however, be prejudiced by severing the claims.
Again, much of the evidence and testimony that would need to be presented at trial
against PrimeCare would likewise need to be presented against Correctional
Defendants. This means that Plaintiffs would need to present the same evidence and
witnesses twice—or three times if the other motion to sever were granted. This is a
large amount of duplicative cost and effort that may be avoiding by maintaining a
unified action.
These considerations collectively weigh against severing claims against
PrimeCare from this action. PrimeCare’s motion to sever will therefore be denied.
2. 	Correctional Defendants’ Motion
Correctional Defendants seek severance on two grounds. First, they assert that
they have been misjoined.50 Second, they argue that, under the relevant factors,
severance is appropriate. 51
As to the issue of misjoinder, misjoinder “occurs when there is no common
question of law or fact or when . . . the events that give rise to the plaintiff’s claims
50 	Doc. 291 at 13-17.
51 	Id. at 18-26.
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against defendants do not stem from the same transaction.” 52 When parties are
misjoined, courts may drop defendants from the matter, or sever the claims and have
the matters proceed separately. 53
“Courts generally apply a case-by-case approach when considering whether
the facts of several claims constitute a single transaction or occurrence or a series of
transactions or occurrences.”54 “Transaction’ is a word of flexible meaning, and may
comprehend a series of many occurrences, depending not so much upon the
immediateness of their connection as upon their logical relationship.”55 To determine
whether claims are part of a single transaction or occurrence, courts “must engage
in ‘a detailed analysis . . . to determine whether the claims involve: (1) many of the
same factual issues; (2) the same factual and legal issues; or (3) offshoots of the
same basic controversy between the parties.’” 56
Joinder is therefore proper when there is “evidentiary overlap in the facts
giving rise to the cause of action against each defendant.” 57 “In other words,” the
claims “must share an aggregate of operative facts.” 58 As the Supreme Court of the
United States has stated, “the impulse is toward entertaining the broadest possible
52 	DirecTV, Inc. v. Leto, 467 F.3d 842, 844 (3d Cir. 2006).
53 	Id. at 845.
54 	Russell v. Chesapeake Appalachia, L.L.C., 305 F.R.D. 78, 81 (M.D. Pa. 2015) (internal
quotation marks omitted).
55 	Id. (internal quotation marks omitted).
56 	Id. (quoting Xerox Corp. v. SCM Corp., 576 F.2d 1057, 1059 (3d Cir. 1978)).
57 	In re EMC Corp., 677 F.3d 1351, 1358 (Fed. Cir. 2012).
58 	Id.
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scope of action consistent with fairness to the parties; joinder of claims, parties and
remedies is strongly encouraged.” 59
The facts here satisfy the transaction or occurrence requirement and are
certainly offshoots of the same basic controversy, sharing an aggregate of operative
facts. Taking a macro view, these claims involve the same core facts related to
Riley’s detention, and the use of force claims are analyzed under the same legal
standards.
In the micro, these claims become far more inextricably intertwined. While
Plaintiffs’ claims against Booking Defendants and Prison Defendants may, in
isolation, be somewhat disconnected, the Court cannot ignore the claims against
PrimeCare and the interconnected nature of the claims against all three groups of
defendants.
As previously discussed in addressing PrimeCare’s motion to sever, the
claims against PrimeCare in particular are related to claims against the Correctional
Defendants. It would be impossible to sever claims between any set of defendants
and keep the facts sensible and intelligible to the jury—to attempt to sever any set
of claims from the others would simply be too confusing and would obscure the
entirety of the picture for the jury. As to the elements for a use-of-force-claim, 60 the
59 	United Mine Workers of Am. v. Gibbs, 383 U.S. 715, 724 (1966).
60 	When analyzing use of force claims for a pretrial detainee like Riley, the factfinder must
consider: “the relationship between the need for the use of force and the amount of force used;
the extent of the plaintiff’s injury; any effort made by the officer to temper or to limit the
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jury could not reasonably understand the need for the use of force and the severity
of 	the 	security 	problem 	the 	correctional 	officers 	may 	have 	faced 	without
understanding Riley’s mental state. Similarly, it would be difficult for the jury to
understand extent of the injuries cause by a specific use of force without knowing
about prior uses of force, so as to distinguish between the incidents.
Because these claims are all offshoots of the same basic controversy, this
Court finds that they are properly joined. As such, the Court will turn to the three
factors 	in 	determining 	whether 	severance 	is 	nevertheless 	appropriate. 	A 	full
consideration of those factors demonstrates that severance is not appropriate.
First, the legal issues for Correctional Defendants are identical—although
factually distinct—and would require similar evidentiary proof. While specific
evidence as to each use of force will be distinct, as just discussed with regard to
misjoinder, the events form part of an interconnected series of occurrences, all of
which must be presented to the jury in order for the jurors to properly understand
any one event within that series. And as previously discussed, the entirety of the uses
of force against Riley and any injuries those uses may have caused must be presented
to the jury so that it may distinguish between which injuries may have been caused
by which defendants.
amount of force; the severity of the security problem at issue; the threat reasonably perceived
by the officer; and whether the plaintiff was actively resisting.” Jacobs v. Cumberland Cnty.,
8 F.4th 187, 194-95 (3d Cir. 2021) (quoting Kingsley v. Hendrickson, 576 U.S. 389, 397
(2015)).
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Moreover, as noted with PrimeCare’s motion, the jury must understand
Riley’s mental health and the Correctional Defendants’ knowledge of his mental
health to assess whether the uses of force were reasonable. Stated differently, a
reasonable jury may well believe that a use of force is objectively unreasonable when
used against an individual known to be suffering severe mental decline who the jury
believes was not acting with any intention to do harm to others, but may well find
such use of force reasonable if they concluded that the officers had limited
knowledge of the mental decline. This information also plays directly into the threat
that an officer may have perceived from Riley.
If the Prison Defendants had knowledge of past use of force against Riley,
why it was applied, and whether it was effective, the jury could also reasonably view
those facts as informing the Prison Defendants in whether a particular use of force
was appropriate or would have been effective. Simply put, the jury must understand
whether the defendants knew of Riley’s mental health issues and treatment, as well
as past uses of force, to determine whether a reasonable officer could have concluded
that a different course of action and less forceful methods were more appropriate
under the circumstances. This factor therefore weighs against severance.
Second, severance would harm, rather than promote, judicial economy.
Again, significant time and effort has been expended in understanding the facts and
resolving the legal issues relevant to these claims, and the parties and Court are
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familiar with the facts and law important in this case. Much of the same evidence is
relevant to claims against the three groups of defendants here and would need be to
repeated in each trial should this matter be split into three separate actions. That
would be a significant waste of judicial resources, and this wastefulness weighs in
favor of denying the motion to sever.
Third, there is no significant danger of prejudice to the defendants from a
single trial. Correctional Defendants argue that they will be prejudiced by the
cumulative presentation of uses of force, which they assert would provoke the jury’s
“sense of horror” and “instinct to punish,” particularly to Booking Defendants, as
Prison Defendants are alleged to have caused Riley’s death.61 But the consequences
that resulted from the two uses of force—i.e. the injuries suffered by Riley—are
clearly and easily distinguishable. While the events are necessary for a complete
understanding of what happened to Riley, the Court discerns no difficulty for the
jury in distinguishing between these events.
Moreover, any potential prejudice may be easily mitigated by clear and proper
limiting instructions providing, for example, that: (1) the jury may not consider any
other use of force employed by other defendants except in narrow circumstances,
such as how that use of force and resultant injuries may have impacted each
defendant’s consideration of whether force used in each specific incident was
61 	Doc. 293 at 21; see id. at 21-23.
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appropriate; and (2) the Booking Defendants’ use of force did not, as a matter of
law, 	cause 	Riley’s 	death. 	While 	Correctional 	Defendants 	maintain 	that
“[i]ndisputably, juries sometimes use evidence for an improper purpose, particularly
when the issue under review involves matters of policing,”62 courts must “presume
that the jury followed the limiting instruction and considered evidence only for the
limited purposes offered.” 63
Relatedly, Correctional Defendants contend that inclusion of evidence against
the Booking Defendants may cause the jury to conclude that a pattern of force led to
the incident involving Prison Defendants.64 Again, this may primarily be addressed
through limiting instructions. And to the extent that Correctional Defendants assert
evidence may be presented that would improperly point the jury to such a
conclusion, any objectionable evidence may be excluded through an appropriate
motion in limine. Finally, Correctional Defendants argue that the sheer volume of
evidence will overwhelm the jury.65 This is not a genuine concern—this Court has
conducted jury trials with far more extensive and complex evidence applied to
multiple defendants with complicated legal claims—such as trademark disputes—
62 	Id. at 22.
63 	United States v. Curry, 158 F.4th 153, 162 (3d Cir. 2025) (ellipses and internal quotation marks
omitted).
64 	Doc. 293 at 23-26.
65 	Doc. 293 at 23.
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and juries have handled those cases without issue. Clear instructions are all that are
required.
Conversely, Plaintiffs would be prejudiced by severance of these claims. As
discussed previously, much of the evidence and testimony that would need to be
presented at trial against any one group of defendants would likewise need to be
presented against the other defendants. This means that Plaintiffs would need to
present the same evidence and witnesses three times. The redundant costs and efforts
associated with three separate trials involving much of the same evidence is a
significant harm to Plaintiffs.
In sum, the relevant considerations weigh against granting this motion to
severe. The motion will therefore be denied.
III. 	CONCLUSION
For the foregoing reasons, the Court concludes that severance of these claims
is 	inappropriate. 	Moreover, 	Plaintiffs’ 	claims 	against 	PrimeCare 	will 	not 	be
dismissed. Accordingly, the pending motions will be denied.
An appropriate Order follows.
BY THE COURT:
s/ Matthew W. Brann
Matthew W. Brann
Chief United States District Judge
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