Conway v. Detroit, City of et al

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
LUCIOUS CONWAY,
Plaintiff,
v.
CITY OF DETROIT, et al.,
Defendants.
/
Case No. 2:25-cv-10517
HONORABLE STEPHEN J. MURPHY, III
LUCIOUS CONWAY,
Plaintiff,
v.
CITY OF DETROIT, et al.,
Defendants.
/
Case No. 2:25-cv-11889
HONORABLE STEPHEN J. MURPHY, III
ORDER CONSOLIDATING CASES
Before the Court are two actions involving the same plaintiff and two of the
same defendants, centered around the same incident. In the earlier-filed case,
Plaintiff Lucious Conway sued the City of Detroit and the Detroit Police Department
after the City denied Plaintiff’s application for a license to purchase a firearm. In the
later-filed case, Conway sued the City of Detroit, the Detroit Police Department, and
Detroit Police Officer Eshad Ali. Compare Conway v. City of Detroit, Case No. 2:25-
cv-10517, ECF No. 1 (E.D. Mich. Feb. 21, 2025) (Murphy, J.), with Conway v. City of
Detroit, Case No. 2:25-cv-11889, ECF No. 1 (E.D. Mich. June 19, 2025) (Murphy, J.).
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The latter case was reassigned to the Court as a companion matter on October 15,
2025. Conway v. City of Detroit, Case No. 2:25-cv-11889, ECF No. 13 (E.D. Mich. Oct.
15, 2025) (Murphy, J.).
The Court may consolidate actions if they “involve a common question of law
or fact.” Fed. R. Civ. P. 42(a). “Whether cases involving the same factual and legal
questions should be consolidated for trial is a matter within the discretion of the trial
court, and the court’s decision is reviewed for abuse of discretion.” Cantrell v. GAF
Corp., 	999 F.2d 	1007, 	1011 	(6th Cir. 	1993). 	“A 	court 	may 	issue 	an 	order 	of
consolidation on its own motion, and despite the protestations of the parties.” Id.
When deciding whether to consolidate, the Court “must consider” several factors:
whether the specific risks of prejudice and possible confusion are
overborne by the risk of inconsistent adjudications of common factual
and legal issues, the burden on parties, witnesses and available judicial
resources posed by multiple lawsuits, the length of time required to
conclude multiple suits as against a single one, and the relative expense
to all concerned of the single-trial, multiple-trial alternatives.
Innovation Ventures, L.L.C. v. Custom Nutrition Labs., L.L.C., 451 F. Supp. 3d 769,
793 (E.D. Mich. 2020) (quoting Cantrell, 999 F.2d at 1011).
The two cases in the caption satisfy the criteria for consolidation because they
involve common questions of law and fact. Both complaints concern the City’s denial
of Plaintiff’s application for a license to purchase a firearm from February 2025. The
latter case names a new defendant, Officer Ali, and includes additional allegations
related to his failure to activate his body-worn camera equipment. Conway v. City of
Detroit, Case No. 2:25-cv-11889, ECF No. 1, PageID.3–4 (E.D. Mich. June 19, 2025)
(Murphy, J.). Shared rather than individual issues predominate, so there is little risk
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for confusion. See Innovation Ventures, 451 F. Supp at 794. The risk for prejudice
resulting from consolidation is likewise low because the earlier-filed case is still in
discovery and the dispositive motion cutoff is more than a month away. Consolidation
can only increase the speedy and efficacious administration of justice for all claims
because the discovery and evidence already taken in the first case will overlap with
the information and evidence that will be relevant for discovery purposes in the
second case. The factors thus counsel in favor of deciding the claims as a single case.
Accordingly, the Court will order the Clerk of Court to consolidate the cases.
WHEREFORE, it is hereby ORDERED that the Clerk of Court must
CONSOLIDATE Conway v. City of Detroit, Case No. 2:25-cv-11889 (E.D. Mich. June
19, 2025) with Conway v. City of Detroit, Case No. 2:25-cv-10517 (E.D. Mich. Feb. 21,
2025).
IT IS FURTHER ORDERED that the Clerk of Court must CLOSE Conway
v. City of Detroit, Case No. 2:25-cv-11889 (E.D. Mich. June 19, 2025).
IT IS FURTHER ORDERED that the Clerk of Court must ADD Eshad Ali
as a defendant in the case.
SO ORDERED.
s/ Stephen J. Murphy, III
STEPHEN J. MURPHY, III
United States District Judge
Dated: October 21, 2025
I hereby certify that a copy of the foregoing document was served upon the parties
and/or counsel of record on October 21, 2025, by electronic and/or ordinary mail.
s/ R. Loury
Case Manager
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