Full opinion text
MARCUS, Circuit Judge: This case involves various claims of race discrimination brought by eighteen current and former Fulton County Sheriffs Department employees individually and on behalf of all similarly situated white employees of the Sheriffs Department against Fulton County, Georgia and Sheriff Jacquelyn H. Barrett, in her official and individual capacities (collectively, “Defendants”). Plaintiffs sued Fulton County and Sheriff Barrett alleging that Fulton County maintained a “policy or custom” of racial discrimination in employment decisions, that Fulton County and the Sheriffs Department engaged in a “pattern or practice” of employment discrimination, and specifically that Fulton County and Sheriff Barrett intentionally discriminated on the basis of race with respect to discipline, promotions, transfers, reclassifications, promotional examinations, restorations of rank, and appointments to unclassified positions. Defendants now appeal from a jury verdict entered for most of the Plaintiffs finding that Fulton County maintained a policy or custom of discrimination against white employees and that Sheriff Barrett intentionally discriminated against white employees. After a thorough review of the record, we affirm in part, reverse in part, and remand for further proceedings consistent with this opinion. I. In September 1993, Plaintiffs filed their complaint as a class action alleging a “pattern or practice” of employment discrimination against white personnel of the Fulton County Sheriffs Department in the terms and conditions of employment in violation of 42 U.S.C. § 1981, 42 U.S.C. § 1983, and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq. In April 1994, the district court, finding the requisite numerosity, commonality, typicality, and adequacy of representation, certified under Rule 23(b)(2) of the Federal Rules of Civil Procedure the following class: All present and future sworn white employees of the Fulton County Sheriffs Department and all past sworn white employees who allege discriminatory acts by Defendants within the applicable statute of limitations. On June 12, 1996, after an extended trial, the jury awarded damages to fifteen of the eighteen Plaintiffs and the district court entered judgment. On July 8, 1996, Plaintiffs moved to amend the judgment, requesting injunctive relief and back pay, and, on July 10, 1996, the district court vacated the judgment. Thereafter, the district court entered a modified judgment for damages, backpay, individual equitable relief, and class-based injunctive relief. The jury verdict and final judgment included the following for each Plaintiff: 1. Major A.M. Alexander — The jury found that the Defendants had discriminated against Alexander with respect to assignments or transfers and that he had been disciplined in whole or in part because of his race. The jury awarded Alexander $125,000 in compensatory damages against both Fulton County and Sheriff Barrett and $25,000 in punitive damages against Sheriff Barrett for discriminatory assignments or transfers. The jury also awarded Alexander $2,800 in back pay, an additional $125,000 in compensatory damages against Fulton County and Sheriff Barrett, and $25,000 in punitive damages against Sheriff Barrett for his suspension. The district court also ordered that the record of disciplinary action against Alexander be expunged from his Sheriffs Department file. 2. Sergeant Charles “Tony” Alexander — The jury awarded Charles Alexander $15,000 in compensatory damages because of Sheriff Barrett’s failure to restore Alexander’s rank after his voluntary demotion from sergeant to deputy. The district court ordered the Defendants to recalculate Alexander’s retirement benefits and other employee benefits to reflect any changes that would have occurred had his rank been restored. 3. Sergeant Joseph Bantin — The jury found in favor of Bantin on his claims that Sheriff Barrett did not consider him for appointment to the unclassified positions of captain or major on account of his race, and that he was not permitted to compete in the promotional process for the rank of classified lieutenant, also because of race. Finally, the jury returned a verdict for the Defendants on Bantin’s claim that he had not been considered for reclassification because of his race. The jury awarded Bantin $10,000 in compensatory and $5,000 in punitive damages based on its finding of discrimination against Bantin in the promotional process. 4. Sergeant Billy Bolt — The jury found that Bolt was wrongfully not appointed to the classified position of lieutenant in June 1993 because of his race and awarded him $20,000 in compensatory damages and $5,000 in punitive damages. The district court also entered an award of $1,000.98 in back pay and ordered the Defendants to reclassify Bolt as a lieutenant providing him with the pay grade, employee benefits, and seniority he would have achieved had he been appointed to the rank of classified lieutenant on June 1,1993. 5. Sergeant Denise Brooks — The jury found that Brooks was not selected for appointment to the unclassified positions of captain or major due to her race. The jury concluded that Brooks should have been appointed as an unclassified captain in June 1993 and awarded her $10,000 in compensatory damages and $10,000 in punitive damages. The jury also found that she was discriminated against with respect to assignments or transfers and awarded her an additional $25,000 in compensatory damages and $5,000 in punitive damages. The district court also ordered the Defendants to provide Brooks with the pay grade, employee benefits, and seniority she would have achieved had she been appointed to captain on June 1,1993. 6. Lieutenant Robert Fox — The jury found that Fox was not appointed to the position of unclassified captain in March 1993 and was transferred to a position in the Jail against his will in 1994 because of race. The jury awarded Fox $20,000 in compensatory damages and $10,000 in punitive damages on his failure to promote claim. It awarded him an additional $50,000 in compensatory damages and $10,000 in punitive damages on his discriminatory assignment or transfer claim. The district court ordered the Defendants to recalculate Fox’s retirement and other benefits as if he had been appointed to an unclassified captain position on March 1,1993. 7. Captain Gary Gettis — The jury found that Gettis was not appointed to the unclassified positions of captain or major due to his race. The jury concluded that in the absence of discrimination, Gettis would have been appointed to an unclassified captain position in June 1993, and awarded him $10,000 in compensatory damages and $10,000 in punitive damages. The district court also awarded Gettis $2,290.59 in back pay, the amount he would have received had he been appointed to an unclassified captain position in June 1993, and ordered the Defendants to recalculate Get-tis’ retirement and other employee benefits as if he had been appointed to an unclassified captain position on June 1, 1993. 8. Corporal Sara Henderson — The jury found that Henderson was not considered for appointment to the unclassified positions of captain or major on account of her race. However, the jury found against Henderson on her claim that she was denied promotions to the positions of classified corporal and sergeant in 1993 because of race. The jury did not award her any damages. 9. Sergeant Kathy Jones — The jury found that Jones was denied transfers outside the Jail because of race and awarded her $10,000 in compensatory damages and $5,000 in punitive damages. The district court declined to award injunctive relief to Jones. 10. Lieutenant Carolyn Masson — The jury found that Masson was not considered or selected for appointment to the unclassified positions of captain or major due to her race and that she was also discriminated against with regard to assignments or transfers because of her race. As for not selecting her to an unclassified position, the jury concluded that Masson should have been appointed to an unclassified captain position in June 1993 and awarded her $10,000 in compensatory damages and $10,000 in punitive damages. As for its findings concerning the assignments or transfers, the jury awarded Masson an additional $50,000 in compensatory damages and $10,000 in punitive damages. The district court also awarded Masson $5,412.99 in back pay to compensate her for wages she would have received had she been appointed to the position of unclassified captain in June 1993. The court also ordered the Defendants to provide Masson with the pay grade, employee benefits, and seniority she would have earned had she been appointed to the position of captain on June 1, 1993. 11. Corporal Donnie McBee — Although the jury found for McBee on his claim that he was not considered for appointment to the unclassified positions of captain or major because of his race, it found his failure to be selected for these positions was not on account of his race. The jury also concluded McBee had not been discriminated against with respect to assignments or transfers. Accordingly, the jury did not award McBee any damages. 12. Corporal Guerry “Bubba” Moore— The jury found that Moore was not considered for appointment to the unclassified positions of captain or major because of race, but found that his failure to be selected for appointment to these positions was not on account of race. The jury did find, however, that Moore had been .discriminated against on the basis of race with regard to assignments or transfers and awarded him $10,000 in compensatory damages and $5,000 in punitive damages. The district court entered judgment in these amounts but declined to enter any individual injunc-tive relief. 13. Sergeant James NeSmith — The jury found for NeSmith on his claims that he was discriminated against because of race with regard to promotions, assignments or transfers, and discipline. The jury awarded him $10,000 in compensatory damages and $10,000 in punitive damages on his unclassified position non-selection claim. The jury also awarded him $40,000 in compensatory damages and $8,000 in punitive damages on his discriminatory assignment or transfer claim, and an additional $30,000 in compensatory damages and $7,000 in punitive damages on his discriminatory discipline claim. The district court also awarded NeSmith $2,156.83 in back pay to compensate him for wages he would have received had he been promoted to the position of unclassified captain in March 1993, and ordered the Defendants to provide NeSmith with the pay grade, employee benefits, and seniority he would have earned had he been promoted to the position of unclassified captain on March 1,1993. 14. Sergeant Joan Paschal — The jury found for Paschal on her claim that she was not considered for appointment to the unclassified positions of captain or major due in whole or in part to her race, but it awarded her no monetary relief, and the district court ordered no injunctive relief. 15.Sergeant Heidi Schaefer — The jury found that Schaefer was not considered for appointment to the unclassified positions of captain or major on account of her race and that she was discriminated against because of race with respect to assignments or transfers. The jury also concluded that Schaefer had not been permitted to compete in the promotional process for the rank of classified lieutenant in 1993 because of her race. Accordingly, the jury awarded Schaefer $10,000 in compensatory damages and $5,000 in punitive damages for the assignment or transfer claim, and an additional $10,000 in compensatory damages and $5,000 in punitive damages for the promotional process claim. 16. Sergeant Robert Smith — The jury found that Smith was not reclassified as a classified sergeant until July 1994, and was not permitted to compete in 1993 in the promotional process for the position of classified lieutenant because of his race. Although the jury found that Smith was the victim of discrimination when he was not considered for appointment to the unclassified positions of captain or major, it concluded that his failure to be selected was not the result of discrimination. The jury also determined that Smith was not discriminated against with respect to assignments or transfers. As for his reclassification claim, the jury found that Smith should have been reclassified as a classified sergeant in November 1992 and awarded him $10,000 in compensatory damages and $0 in punitive damages. As for his promotional process claim, the jury awarded Smith $10,000 in compensatory damages and $5,000 in punitive damages. Finally, the district court ordered the Defendants to provide Smith with the pay grade, employee benefits, and seniority he would have achieved had he been promoted to the rank of classified sergeant on November 1,1992. 17. Sergeant Benjamin Steele — The jury found that while Steele was not considered for appointment to the unclassified positions of captain or major on account of race, his failure to be selected for these positions was not due to his race. The jury did find that Steele was discriminated against with respect to assignments or transfers but not with respect to reclassifications. ■ Based on finding discrimination on Steele’s assignment or transfer claims, the jury awarded Steele $10,000 in compensatory damages and $5,000 in punitive damages. 18. Corporal Robert Upshaw — Finally, the jury found that while Upshaw was not considered for appointment to the unclassified positions of captain or major because of his race, his failure to be selected for these positions was not on account of race. The jury did find, however, that Upshaw’s rank of classified lieutenant was not restored after his voluntary demotion to deputy because of his race. As for this claim, the jury awarded Upshaw $20,000 in compensatory damages but no punitive damages. The district court also ordered Defendants to promote Upshaw to the rank of classified lieutenant retroactive to March 1, 1993, and to adjust his pay grade, employee benefits, and seniority accordingly. The district court decertified the class after trial observing that because of the different types of discrimination claims alleged, Plaintiffs did not satisfy the commonality and typicality prerequisites of a class action. The court also expressed doubt as to whether the members of the class were really so numerous as to warrant class certification. In January 1997, the district court denied the Defendants’ motion for judgment as a matter of law and entered final judgment for the Plaintiffs. II. A brief description of the structure, function, and hierarchy of the Fulton County Government offices at issue is necessary to understand the resolution of this appeal. We begin with Defendant Fulton County which is administered by the Fulton County Board of Commissioners (“Board”), in turn made up of seven Commissioners elected by the voters of Fulton County to four-year terms. The Board sets Fulton County governmental policy and approves departmental budget requests. Fulton County voters elect the Sheriff every four years. On December 14,1992, defendant Jacquelyn Barrett took office as the Sheriff of Fulton County, Georgia. As of August 1993, the Fulton County Sheriffs Department had 629 sworn law enforcement officers. Among those officers, 521, or 83%, were black. The Sheriffs Department, like all other Fulton County departments, uses the services of the Fulton County Personnel Department. The Personnel Board is appointed by the Board of Commissioners and is the major decision-making authority within the Personnel Department. The Personnel Department is responsible for the County’s human resources system, which designates the positions of Fulton County employees as being either “classified” or “unclassified.” Classified jobs comprise the vast majority of the jobs in the Sheriffs Department and are explicitly subject to civil service-type protections. For those jobs, the Personnel Department advertises the positions available, noting the minimum qualifications required for each, and thereafter processes all applications. In reviewing them, the Board determines whether an applicant meets the “published” minimum requirements. If the applicant does not meet the requirements the Board notifies the applicant of this finding and the applicant is given thirty days to provide the Board with additional information and contest the finding. But, if the Personnel Board finds that an applicant meets the minimum qualifications, the applicant receives notification of the next scheduled promotions test. The Personnel Board then administers a written test. If an applicant passes that, he is eligible to take an oral examination given by high-ranking officers in the Sheriffs Department. Thereafter, if an applicant passes both the written and oral tests, his name appears on a list of eligible applicants ranked by examination scores. When an opening for a classified position arises, the Sheriff promotes an individual from the list in rank designated order. Each list expires after six months, and the officers who are not promoted from the list but wish to be considered for future promotions must go through the entire process again. Unclassified jobs, in contrast, are more like political appointments. In Sheriff Barrett’s administration, they consist of positions with the rank of captain or higher. Notably, a department head such as Sheriff Barrett with appointment authority does not have to advertise for open unclassified positions, is not required to employ the services of the Personnel Department, and can dismiss an unclassified employee at her pleasure. The Personnel Board hears appeals of classified employees who have suffered demotions, suspensions, or dismissals when the employee alleges that the action was taken for personal, political, or religious reasons. The Personnel Board also considers “reclassification” applications. The Grievance Review Committee hears classified and unclassified employees’ appeals of employment decisions made by superiors. Its review of classified employees’ grievances, however, is limited to cases not falling under the jurisdiction of the Personnel Board. This Committee is comprised of two Fulton County non-supervisory employees, two members drawn from the supervisory ranks or management appointed by the Board of Commissioners, and one person who is not employed by Fulton County and who is selected by the other members. According to Committee procedure, an employee’s chain of command first reviews and considers a grievance. If the employee cannot establish a satisfactory resolution through the chain of supervision, the grievance is passed to the Personnel Department which logs in the grievance. The Personnel Department then forwards the complaint to the Grievance Review Committee Chairperson who schedules a hearing. After the Grievance Review Committee conducts a hearing, the Committee may recommend settlement orders which are subject to approval by the County Manager. Elected officials such as Sheriff Barrett are not obligated to accept and implement the recommendations of the Grievance Review Committee, but, as a practical matter, they usually do. Finally, the Fulton County Sheriffs Department consists of several Divisions. The Jail Division runs the Fulton County Jail and administers prisoner transfers. The Jail Division is by far the largest of the Sheriffs Departments, with oyer 500 employees. Next in size is the Court Services Division which provides security to Fulton County courthouses and individual courtrooms. Other Divisions include the Service Division, the Office of Professional Standards, and the Bonding Division. The Service Division is responsible for the service of warrants and civil processes. The Office of Professional Standards handles investigations into alleged wrongdoings by Sheriffs Department employees and conducts background investigations on new applicants. The Bonding Division manages the Department’s interaction with bonding companies, as well as the whole bonding process. Upon taking office, Sheriff Barrett created the Community Relations Division and the Research and Planning Division. The Community Relations Division performs various crime prevention activities, and serves as a liaison between the Sheriff and the community. The Research and Planning Division studies issues that the Sheriff believes will be important and prepares the Department’s Policy and Procedures Manual. III. On appeal we consider six broad challenges to the proceedings below: first, that the district court erred in denying qualified immunity to Sheriff Barrett; second, that it erred in concluding Fulton County is liable under section 1983; third, that the court should have granted Defendants’ motion to sever Plaintiffs’ individual claims; fourth, that the district court wrongfully admitted into evidence certain statistical and non-statistical evidence that was both irrelevant and unfairly prejudicial; fifth, that the court erred in its jury instructions; and finally, that the trial court erroneously denied Defendants’ motions for judgment as a matter of law because the evidence was plainly insufficient to support any of the individual Plaintiffs’ claims. We consider each claim in turn. A. We examine first Sheriff Barrett’s belated argument raised for the first time in the Defendants’ motion for judgment as a matter of law that she is protected, in her individual capacity, from civil damages by the doctrine of qualified immunity because the Plaintiffs failed to demonstrate that her conduct violated their clearly established statutory or constitutional rights. We review de novo the district court’s denial of qualified immunity. Belcher v. City of Foley, 30 F.3d 1390, 1395 (11th Cir.1994). Under qualified immunity, “government officials performing discretionary functions generally are shielded from liability for civil damages insofar as their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have known.” Harlow v. Fitzgerald, 457 U.S. 800, 818, 102 S.Ct. 2727, 73 L.Ed.2d 396 (1982). “For the law to be clearly established to the point that qualified immunity does not apply, the law must have earlier been developed in such a concrete and factually defined context to make it obvious to all reasonable government actors, in the defendant’s place, that ‘what he is doing’ violates federal law.” Lassiter, v. Alabama A&M Univ., Bd. of Trustees, 28 F.3d 1146, 1149 (11th Cir.1994) (en banc) (quoting Anderson v. Creighton, 483 U.S. 635, 640, 107 S.Ct. 3034, 3039, 97 L.Ed.2d 523 (1987)). And “ ‘[f]or qualified immunity to be surrendered, pre-existing law must dictate, that is, truly compel (not just suggest or allow or raise a question about), the conclusion for every like-situated, reasonable government agent that what defendant is doing violates federal law in the circumstances.’ ” Jenkins by Hall v. Talladega City Bd. of Educ., 115 F.3d 821, 823 (11th Cir.1997) (en banc) (quoting Lassiter, 28 F.3d at 1150). In analyzing a defense of qualified immunity, we first consider whether Sheriff Barrett was acting within the scope of her discretionary authority when the alleged wrongful acts occurred. Evans v. Hightower, 117 F.3d 1318, 1320 (11th Cir. 1997). If Sheriff Barrett has met this burden, the Plaintiffs must then demonstrate that she violated clearly established law based upon objective standards. Id. On this record, it is undisputed that the Sheriff was acting within the scope of her discretionary authority when she made the various employment decisions at issue. Moreover, there can be no doubt that in December 1992, when Sheriff Barrett assumed office, it was clearly established that intentional discrimination in the workplace on account of race violated federal law. See Smith v. Lomax, 45 F.3d 402, 407 (11th Cir.1995); Yeldell v. Cooper Green Hosp., Inc., 956 F.2d 1056, 1064 (11th Cir.1992) (citing Washington v. Davis, 426 U.S. 229, 239-41, 96 S.Ct. 2040, 2047-48, 48 L.Ed.2d 597 (1976)); Busby v. City of Orlando, 931 F.2d 764, 775 (11th Cir.1991) (same); Brown v. City of Ft. Lauderdale, 923 F.2d 1474, 1478 (11th Cir. 1991) (same). Sheriff Barrett, however, relying on Foy v. Holston, 94 F.3d 1528 (11th Cir.1996), argues that she is entitled to qualified immunity because she had a “substantial lawful motive” for making each of the employment decisions in question. In Foy, the parents of children removed or threatened with removal from a religious community sued the responsible state social service employees under section 1983 claiming that the state employees acted out of hostility toward the parents’ religious beliefs. The social service employees moved for summary judgment claiming qualified immunity. We held that the defendants were entitled to qualified immunity because it was [not] already clearly established when [the employees] acted that no child custody worker could lawfully act-that is, do what Defendants did-to protect children in the circumstances of this case if the worker also acted, in part, out of hostility toward the parent’s religion.” Id. at 1536. Subsequently, we have observed that the holding in Foy “rested primarily on the existence of an indisputable and adequate lawful motive on the part of the social service employees such that reasonable officials would disagree as to the legality of their conduct.” Johnson v. City of Ft. Lauderdale, 126 F.3d 1372, 1379 (11th Cir.1997) (emphasis added). In this case, however, the jury squarely found that Sheriff Barrett intentionally discriminated against many white law enforcement officers on account of race, and, in so doing, unambiguously rejected her proffered non-discriminatory reasons for her employment decisions. Foy, therefore, is inapposite. Based on a painstaking review of this record, we are satisfied that a reasonable jury could find Sheriff Barrett intentionally made race-based employment decisions in violation of Plaintiffs’ clearly established rights. As a result, the district court properly denied the Defendants’ motion for judgment as a matter of law because of qualified immunity. See Von Stein v. Brescher, 904 F.2d 572, 578 (11th Cir.1990) (“[I]f there is substantial evidence opposed to the motions [for judgment as a matter of law], that is, evidence of such quality and weight that reasonable and fair-minded men in the exercise of impartial judgment might reach different conclusions, the motions should be denied, and the case submitted to the jury.’ ”) (quoting Boeing Co. v. Shipman, 411 F.2d 365, 374-75 (5th Cir.1969) (en banc)). B. Next, the Defendants argue that the district court erred in denying their motion for judgment as a matter of law as to Fulton County’s liability under section 1983. Specifically, they claim that Sheriff Barrett did not have “final policy-making authority” over personnel decisions and that Fulton County had no “policy or custom” of employment discrimination, thereby foreclosing County liability for any of the many challenged employment decisions. Whether the County may properly be held liable under section 1983 makes no practical difference to the outcome of the case for three independent reasons. First, to the extent that Plaintiffs complied with Title VIPs preconditions to suit, the County may properly be held liable under Title VII for all of the claims Plaintiffs press under section 1983. Second, none of the Plaintiffs’ total damages awards exceeded the relevant statutory limitation of $300,-000 imposed by Title VII. Therefore, we need not consider whether the awards would be permissible under section 1983. Third, as Plaintiffs conceded before the district court, they may not be awarded punitive damages against the County. See Newport v. Fact Concerts, Inc., 453 U.S. 247, 258-61, 101 S.Ct. 2748, 2755-56, 69 L.Ed.2d 616 (1981); Healy v. Town of Pembroke Park, 831 F.2d 989, 991 (11th Cir.1987). Because Title VII provides an alternative basis for liability in this case, we need not, and will not, address the purely academic question of whether the County could also properly have been found liable under section 1983. C. Defendants also broadly allege that the district court erred in so far as it tried each of the Plaintiffs’ claims together. After discovery, Defendants moved to sever Plaintiffs’ individual claims of discrimination contending that the joint trial of these claims would confuse the jury and unfairly prejudice their defense. The district court rejected this motion. We review a district court’s joinder of Plaintiffs’ claims and denial of severance for abuse of discretion. Nor-Tex Agencies, Inc. v. Jones, 482 F.2d 1093, 1100 (5th Cir.1973). Although we recognize that unfair prejudice may result from trying together the claims of multiple Plaintiffs alleging different types of discrimination, we discern no abuse of discretion in the district court’s decision to join the Plaintiffs’ claims in this case. Among other things, the Federal Rules of Civil Procedure provide that “[a]ll persons may join in one action as plaintiffs if they assert any right to relief jointly, severally, or in the alternative in respect of or arising out of the same transaction, occurrence, or series of transactions or occurrences and if any question of law or fact common to all these persons will arise in the action.” Fed.R.Civ.P. 20(a). See also Grayson v. K Mart Corp., 79 F.3d 1086, 1097 (11th Cir.1996). A party seeking joinder of claimants under Rule 20 must establish two prerequisites: 1) a right to relief arising out of the same transaction or occurrence, or series of transactions or occurrences, and 2) some question of law or fact common to all persons seeking to be joined. See Fed. R.Civ.P. 20(a). Plainly, the central purpose of Rule 20 is to promote trial convenience and expedite the resolution of disputes, thereby eliminating unnecessary lawsuits. See Mosley v. General Motors Corp., 497 F.2d 1330, 1332 (8th Cir.1974). The Federal Rules, however, also recognize countervailing considerations to judicial economy. Rule 42(b), for example, provides for separate trials where the efficiency of a consolidated trial is outweighed by its potential prejudice to the litigants. See Fed.R.Civ.P. 42(b); Grayson, 79 F.3d at 1097. The Supreme Court has instructed the lower courts to employ a liberal approach to permissive joinder of claims and parties in the interest of judicial economy: “Under the Rules, the impulse is towards entertaining the broadest possible scope of action consistent with fairness to the parties; joinder of claims, parties and remedies is strongly encouraged.” United Mine Workers v. Gibbs, 383 U.S. 715, 724, 86 S.Ct. 1130, 1137, 16 L.Ed.2d 218 (1966). In determining what constitutes a transaction or occurrence for the purposes of Rule 20(a), courts have looked for meaning to Fed.R.Civ.P. 13(a) governing compulsory counterclaims. See Mosley, 497 F.2d at 1333. For the purposes of Rule 13(a), “ ‘[transaction’ is a word of flexible meaning. It may comprehend a series of many occurrences, depending not so much upon the immediateness of their connection as upon their logical relationship.” Moore v. New York Cotton Exchange, 270 U.S. 593, 610, 46 S.Ct. 367, 371, 70 L.Ed. 750 (1926) (interpreting the compulsory counterclaim provision of former Equity Rule 30). Accordingly, “all ‘logically related’ events entitling a person to institute a legal action against another generally are regarded as comprising a transaction or occurrence.” Mosley, 497 F.2d at 1333. Several courts have concluded that allegations of a “pattern or practice” of discrimination may describe such logically related events and satisfy the same transaction requirement. In Mosley, perhaps the leading case on the joinder of Title YII plaintiffs under Rule 20, see 4 Lex K. Larson, Employment Discrimination, § 78.05, at 28-29 (2d ed.1994), ten black plaintiffs alleged that General Motors had a general policy of discrimination against black employees. The trial court had ordered the severance of the claims, concluding that the allegations presented a variety of issues and had little relationship to one another. Mosley, 497 F.2d at 1332. The Eighth Circuit reversed the trial court’s order to sever plaintiffs’ claims, concluding that, based on its reading of Rule 20, the General Motors policy “purportedly designed to discriminate against blacks in employment ... [arose] out of the same series of transactions and occurrences.” Id. at 1334. The court held that “[s]ince a ‘state-wide system designed to enforce the registration laws in a way that would inevitably deprive colored people of the right to vote’ was determined to arise out of the same series of transactions or occurrences, we conclude that a company-wide policy purportedly designed to discriminate against blacks in employment ... arises out of the same series of transactions or occurrences” Id. at 1333-34 (quoting United States v. Mississippi, 380 U.S. 128, 142, 85 S.Ct. 808, 815-16, 13 L.Ed.2d 717 (1965)). See also Blesedell v. Mobil Oil Co., 708 F.Supp. 1408, 1422 (S.D.N.Y.1989) (“A company-wide policy purportedly designed to discriminate against females in employment arises out of the same series of transactions or occurrences.”); King v. Pepsi Cola Metro. Bottling Co., 86 F.R.D. 4, 6 (E.D.Pa.1979) (noting that allegations of a “pervasive policy of discrimination” by the employer bring the “complaints of individual Plaintiffs under the rubric of the ‘same series of transactions’ ”); Vulcan Soc’y of Westchester Cty. v. City of White Plains Fire Department, 82 F.R.D. 379, 387 (S.D.N.Y.1979) (stating that transaction requirement met where Plaintiffs and would-be Plaintiffs claimed discriminatory policies and practices which included a series of exams allegedly used to discriminate against blacks). The second prong of Rule 20 does not require that all questions of law and fact raised by the dispute be common, but only that some question of law or fact be common to all parties. See Mosley, 497 F.2d at 1334. Several courts have found that the question of the discriminatory character of Defendants’ conduct can satisfy the commonality requirement of Rule 20. See Mosley, 497 F.2d at 1334 (finding that whether the threat of a racially discriminatory policy hangs over a racial class is a question of fact common to all the members of the class); Blesedell, 708 F.Supp. at 1422 (noting that “[i]n employment discrimination cases under Title VII, courts have found that the discriminatory character of a defendant’s conduct is common to each plaintiffs recovery”); cf. Grayson, 79 F.3d at 1095-96 (suggesting that “a unified policy, plan, or scheme of discrimination” can satisfy Rule 20’s commonality requirement). On the other hand, the prejudicial effects of other witnesses’ alleged discriminatory experiences may outweigh their probative value where, for example, the alleged discrimination occurs during different time periods, see, e.g., Annis v. County of Westchester, 136 F.3d 239, 247 (2d Cir. 1998); Williams v. The Nashville Network, 132 F.3d 1123, 1130 (6th Cir.1997), different supervisors make the challenged decisions, see, e.g., Annis, 136 F.3d at 246-47; Williams, 132 F.3d at 1130; Mooney v. Aramco Servs. Co., 54 F.3d 1207, 1221 (5th Cir.1995), or the alleged discrimination happens at geographically removed places, see, e.g., Williams, 132 F.3d at 1130; Mooney, 54 F.3d at 1221. None of these concerns is presented here. In this case, the district court did not abuse its discretion in finding that the Plaintiffs satisfied both requirements for joinder. As for the first requirement, all of the Plaintiffs’ claims stem from the same core allegation that they were subject to a systemic pattern or practice of race-based discrimination against white law enforcement officers by Sheriff Barrett in her first year in office. Plaintiffs all seek relief based on the same series of discriminatory transactions by the same decision-maker in the same department during the same short time frame. As for the second requirement, the discriminatory character of Defendants’ conduct is plainly common to each plaintiffs recovery. The fact that the Plaintiffs suffered different effects — in this case, discrimination in promotions, transfers, assignments, or discipline — from the alleged policy of discrimination did not preclude the trial court from finding a common question of law and fact. See Mosley, 497 F.2d at 1334; Blesedell, 708 F.Supp. at 1422. Alternatively, the Defendants argue that even if the district court did not abuse its discretion in finding proper join-der under Rule 20(a), it did err in failing to sever the Plaintiffs’ cases for trial under Fed.R.Civ.P. 42(b). Grayson, 79 F.3d at 1097. As Rule 42(b) requires the district court to balance considerations of convenience, economy, expedition, and prejudice, the decision to order separate trials naturally depends on the peculiar facts and circumstances of each case. Again, we disturb a district court’s decision not to order separate trials only upon a showing of abuse of discretion. See Bailey v. Board of County Comm’rs, 956 F.2d 1112, 1127-28 (11th Cir.1992). We can discern no abuse of discretion here. Defendants suggest that there was no way to try together the individual claims of the eighteen Plaintiffs, each involving different work histories, employment decisions and prayers for relief, without unfairly prejudicing their defense and confusing the jury. While we acknowledge the real potential for confusion among jurors and for unfair prejudice to a defendant where there are large numbers of Plaintiffs, claims, and defenses, and urge care in joining together in one case multiple claims and multiple claimants, we conclude that in this case the potential for prejudice was minimized because of the core similarities in Plaintiffs’ claims. As we have stated, the claims all center on the core allegation of a systemic pattern of race-based discrimination against white law enforcement officers instigated by Sheriff Barrett during her first year in office. Moreover, the Plaintiffs’ specific claims also overlap substantially. Each plaintiff, with the exception of Major A.M. Alexander, challenged on the grounds of race discrimination Sheriff Barrett’s alleged failure to consider him or her for appointment to unclassified positions. Thirteen Plaintiffs claimed the Sheriff discriminated against each of them in assignments or transfers. In addition to these two main claims, three of the Plaintiffs alleged that they were discriminated against with respect to reclassifications, two claimed that they were discriminated against when Sheriff Barrett failed to restore their rank after voluntary demotions, and two claimed they were disciplined in a discriminatory manner. Furthermore, several of the claims- — discriminatory denial of reclassification, discriminatory denial of restoration of rank, and denial of promotion claims — logically relate or overlap. Finally, each of the Plaintiffs’ claims and the evidence of discrimination undoubtedly are relevant to every other plaintiffs core allegation of systemic discrimination. See Cooper v. Federal Reserve Bank of Richmond, 467 U.S. 867, 876, 104 S.Ct. 2794, 2799, 81 L.Ed.2d 718 (1984) (explaining that evidence of pervasive discrimination against others is admissible if such evidence is similar to the complainant’s experience and tends to establish that “racial discrimination was the company’s standard operating procedure-the regular rather than the unusual practice”) (quoting International Brotherhood of Teamsters v. United States, 431 U.S. 324, 336, 97 S.Ct. 1843, 1855, 52 L.Ed.2d 396 (1977)); Mooney, 54 F.3d at 1221 (holding that “to show relevancy, Trial Plaintiffs had to show that the proffered anecdotal witnesses were sufficiently similar to themselves so that the witnesses’ testimony would have a tendency to show ‘standard [discriminatory] operating procedure’ and a ‘regular rather than unusual practice’ of discrimination.”) (quoting International Brotherhood of Teamsters, 431 U.S. at 336, 97 S.Ct. at 1855). Given the common core of allegations, the substantial overlap of the particular claims, and the logical interconnection of several of the different forms the alleged discrimination took, we are satisfied that the district court did not abuse its discretion in finding that the efficiency of a consolidated trial outweighed the potential for unfair prejudice or jury confusion. While the Defendants also claim that the verdict itself reflects that the joint trial of the eighteen Plaintiffs hopelessly confused the jury, requiring remand and severance, we cannot agree. The verdict actually delivered by the jury, when considered in its entirety, suggests to the contrary that the jury discerned the strengths and weaknesses of the claims of each individual plaintiff. Indeed, the jury denied relief on all claims concerning promotion to unclassified major. The jury also found against two of the four Plaintiffs who claimed that they should have been reclassified, and against five of the ten Plaintiffs who alleged that they were not selected to unclassified captain positions due in part or in whole to their race. See United States v. Bermea, 30 F.3d 1539, 1574 (5th Cir.1994) (stating that “[t]he mixed verdicts returned with respect to [the two of the Defendants] demonstrate that the jury was not confused”); United States v. LaSpesa, 956 F.2d 1027, 1032 (11th Cir.1992) (finding no error in the district court’s denial of motion for severance because, among other reasons, “the jury’s mixed verdict showed, at least to some degree, that it effectively linked the evidence to the appellants and ‘refuted any allegation of compelling prejudice’ ”) (quoting United States v. Hernandez, 921 F.2d 1569, 1578 (11th Cir.1991); United States v. Perlstein, 120 F.2d 276, 281 (3d Cir.1941)) (finding that the jury was not confused by two conspiracies being tried together because they acquitted one defendant and convicted the other). On this record, we cannot say that the district court abused its discretion in not severing Plaintiffs’ individual claims. D. Next, the Defendants challenge the district court’s evidentiary rulings concerning the admissibility of statistical evidence designed to show that white officers were underrepresented in the Sheriffs department, and non-statistical evidence offered to show a custom or practice of discrimination against white employees by Fulton County. Again, we review the district court’s evidentiary rulings for abuse of discretion, see Judd v. Rodman, 105 F.3d 1339, 1341 (11th Cir.1997), and reverse only if the moving party establishes that the ruling resulted in a “substantial prejudicial effect,” Piamba Cortes v. American Airlines, Inc., 177 F.3d 1272, 1305 (11th Cir.1999) (citation and internal quotation marks omitted); see also Fed. R.Evid. 103(a) (“Error may not be predicated upon a ruling which admits or excludes evidence unless a substantial right of the party is affected.... ”); Fed. R.Civ.P. 61 (An erroneous evidentiary ruling is not subject to reversal unless refusal to take such action is “inconsistent with substantial justice.”). When employing an abuse of discretion standard, “we must affirm unless we at least determine that the district court has made a clear error of judgment, or has applied an incorrect legal standard.” SunAmerica Corp. v. Sun Life Assurance Co. of Canada, 77 F.3d 1325, 1333 (11th Cir.1996) (citations and internal quotation marks omitted). While we think the district court erred in admitting both types of evidence, we are satisfied that the error did not result in a substantial injustice to the Defendants. First, the Defendants challenge the district court’s decision to admit five pieces of statistical evidence: (1) testimony concerning and comparing the racial composition of the Sheriffs Department to the general demographics of an eight-county Metropolitan Atlanta area; (2) evidence regarding changes in the overall racial composition of the Sheriffs Department and the workforce in Fulton County over two decades; (3) evidence establishing the change in the racial composition of the general workforce of Fulton County government from the mid-1970’s to the present; (4) testimony regarding the increase in the number of minority employees in Fulton County government from 1985 to 1995 and the concomitant decrease in the number of white employees; and finally, (5) evidence that the overall composition of the County workforce had increased from 22.1% minority in 1972 to 55.9% in 1989, that the percentage of black County Department Heads had increased from zero in 1972 to 40 to 50% in 1990, and that the number of black members of the Board of Commissioners had increased from zero of three to five of seven between 1972 and 1990. We begin by considering the relevance of the first two pieces of evidence generally comparing the racial composition of the Sheriffs Department to the demographics of Fulton County and the eight-county metropolitan Atlanta area to show discrimination by the Sheriffs Department. On occasion, we have regarded as probative of class-based disparate treatment statistics showing that a given minority is “underrepresented” in the work force by comparison with the general population. See, e.g., United States v. City of Miami, 614 F.2d 1322, 1339 (5th Cir.1980) (comparing numbers of Spanish-surnamed City employees with Spanish-surnamed members of the Miami labor force), reh’g granted on other grounds, 664 F.2d 435 (5th Cir.1981). The usefulness of such statistical comparisons, however, is generally limited to claims involving jobs with low skill levels where the applicant pool can be considered roughly coextensive with the general population. See, e.g., City of Richmond v. J.A. Croson Co., 488 U.S. 469, 501, 109 S.Ct. 706, 726, 102 L.Ed.2d 854 (1989) (explaining that “[i]n the employment context, we have recognized that for certain entry level positions or positions requiring minimal training, statistical comparisons of the racial composition of an employer’s work force to the racial composition of the relevant population may be probative of a pattern of discrimination. But where special qualifications are necessary, the relevant statistical pool for purposes of demonstrating discriminatory exclusion must be the number of minorities qualified to undertake the particular task”) (citations omitted) (emphasis added); Hazelwood Sch. Dist. v. United States, 433 U.S. 299, 308 n. 13, 97 S.Ct. 2736, 2742 n. 13, 53 L.Ed.2d 768 (1977) (noting that “[w]hen special qualifications are required to fill particular jobs, comparisons to the general population (rather than to the smaller group of individuals who possess the necessary qualifications) may have little probative value”); International Brotherhood of Teamsters, 431 U.S. at 338 n. 17, 97 S.Ct. at 1856 n. 17 (considering as evidence of intentional discrimination statistics comparing the percentage of black residents in various cities with the percentage of blacks hired as line drivers in those cities). See also Peightal v. Metropolitan Dade County, 26 F.3d 1545, 1553 (11th Cir.1994) (noting that “in order to determine discriminatory exclusion, unskilled positions are compared to a different statistical pool than are jobs requiring special skills”). In a disparate treatment case where low skill jobs are not at issue, “the statistical evidence must be finely tuned to compare the employer’s relevant workforce with the qualified populations in the relevant labor market.” Forehand v. Florida State Hosp. at Chattahoochee, 89 F.3d 1562, 1575 (11th Cir.1996) (disparate treatment class action) (citation and internal quotation marks omitted). In this case, the Plaintiffs consist of current or former sworn law enforcement officers in the Fulton County Sheriffs Department. Plainly, these jobs are not entry level and are not of a “low skill level” within the meaning of International Brotherhood of Teamsters and Hazelwood. The relevant labor pools undoubtedly are narrower than Plaintiffs’ vague comparison to general population figures would suggest, and the comparisons must be more subtle and nuanced. Indeed, for the unclassified captain and major positions, Sheriff Barrett appointed officers with the rank of classified sergeant or higher (in addition to some outside hires). The relevant labor market for these positions, therefore, consisted of all law enforcement officers with at least the rank of sergeant. For reclassifications, the relevant population was comprised of all law enforcement officers eligible for reclassification. For transfers and assignments, the relevant market consisted of all law enforcement officers eligible for the transfer or assignment in question. And for disciplinary actions, the relevant pool was made up of law enforcement officers who had committed the same or similar offenses as the officer who was subject to discipline. Because the general population is not readily qualified for the law enforcement positions at issue in the case, the Plaintiffs cannot show discrimination in hiring simply by comparing the percentage of white sworn officers in the Fulton County Sheriffs Department with the percentage of white residents of Fulton County or metropolitan Atlanta. To show discrimination in hiring for these law enforcement positions, the Plaintiffs would instead have to show a disparity between the percentage of whites hired as law enforcement officers and the percentage of whites in the relevant labor pool of qualified individuals. Because Plaintiffs’ statistical evidence attempts to show discrimination just by looking at the general population rather than at the relevant skilled labor pool, the evidence has no real probative value of whether, within the relevant labor pool, the Sheriffs Department discriminated on the basis of race. As a result, we think the first two pieces of statistical evidence should have been excluded by the trial court. The remaining three pieces of statistical evidence showing the increase in the number of minority employees of Fulton County government also are not relevant to the allegations that the Sheriff discriminated in this case. The evidence was offered to suggest the Sheriffs Department was somehow influenced and encouraged by a larger County-wide policy of discriminating against whites. But this evidence is not probative of a custom or policy in the Sheriffs department for two reasons. First, the statistical evidence reflecting the rising number of minority employees in the County workforce does not alone tend to establish that Fulton County officials initiated and maintained a custom of discrimination against their white employees. It does not ineluctably follow that a rise in the number or percentage of minority employees in the County was caused by a custom or policy of discrimination maintained by County officials. Second, even if a policy or custom of discrimination by the County was somehow demonstrated or even suggested by the rising number of minorities in the County workforce, this evidence standing alone has no bearing on whether such a policy or custom of discrimination was also maintained by the Sheriffs Department. Notably, the Plaintiffs have not shown that the County participated in any way in the employment decisions made by the Sheriff and therefore cannot establish any conneetion between the hiring decisions and policies of the County and those of the Sheriffs Department. As a result, evidence of the racial composition of Fulton County government employees, even if it suggests a policy of racial discrimination by the County, does not make a similar pattern or policy of racial discrimination by the Sheriffs Department against its employees any more or less likely. Although we believe that the district court erroneously admitted the challenged statistical evidence, we are satisfied, after a thorough review of the record, that the error does not warrant reversal for two reasons. First, the district court adequately instructed the jury on the proper weight to be given to the evidence thereby ameliorating any prejudicial effect the evidence might otherwise have had. In instructing the jury on how to evaluate the statistical evidence, the district court stated: “[I]f you find that the Plaintiffs demonstrate a racial disparity, you may consider whether factors other than race account for the disparity and you may consider whether such disparity, if any, caused the specific personnel decisions about which they complain.” The district court’s instruction to consider whether factors other than race account for any statistical disparity, largely cures any error caused by admitting the first two pieces of evidence comparing the racial composition of the Sheriffs Department with the non-relevant general populations of Fulton County and the Metropolitan Atlanta area. The instruction properly focused the jury on the question of whether the statistical disparities were the result of race-based discrimination in the Sheriffs Department or the result of a racially skewed qualified labor pool. By focusing the jury on this critical question of whether the statistical disparities showed that similarly situated black and white individuals were treated differently by the Sheriffs Department — a question in no way answered by the statistical evidence — the district court ensured that the jury did not accord the statistical evidence weight it was not due. Moreover, as for the remaining statistical evidence examining the racial composition of the Fulton County government workforce, we are satisfied that the district court’s instruction to the jury to consider whether the racial disparity reflected in the statistics caused the specific personnel decisions challenged in this case cured any potential injustice caused by the district court’s erroneous admission of this evidence. Again, the district court’s instruction emphasized the need for the jury to find a causal link between the statistical disparities and the decisions made by Sheriff Barrett. No such causal link between the County and the Sheriff was presented. The district court’s instruction, by focusing the jury on the need to find such a link before giving the statistical evidence weight, again ensured that the jurors would not give the evidence weight it did not deserve. Simply put, the district court “sufficiently instructed the jury so that the jurors understood the issues and were not misled” by the statistical evidence erroneously admitted. Carter v. DecisionOne Corp., 122 F.3d 997, 1005 (11th Cir.1997) (citation omitted). See also Nettles v. Electrolux Motor AB, 784 F.2d 1574, 1581 (11th Cir. 1986) (holding that although the district court erroneously admitted certain evidence, the error was not grounds for reversal because the district court correctly focused the jury’s attention on the relevant issue making it “highly unlikely” that the jury gave the evidence undue consideration). Second, although we do find the admissible evidence presented at trial was insufficient to sustain several of the jury’s ver-diets, the verdicts that we do sustain were the product of such one-sided evidence that we find it very unlikely, indeed remote, that the jury could have been swayed erroneously by the wrongfully admitted evidence. See United States v. Mendez, 117 F.3d 480, 486 (11th Cir.1997) (finding harmless the district court’s erroneous introduction of evidence because of the ample evidence supporting the jury’s verdict); Lubbock Feed Lots, Inc. v. Iowa Beef Processors, Inc., 630 F.2d 250, 271 (5th Cir.1980) (upholding a jury verdict despite the district court’s erroneous admission of evidence because “[i]n light of our determination that the evidence was sufficient to support the jury’s finding of an agency relationship even without the challenged testimony, in view of the minor importance of the inadmissible matter, and in light of the district court’s general instructions to the jury, we conclude that the inadmissible matter had no prejudicial impact upon the final outcome of this case”). In six of the nine verdicts that we uphold, Defendants offered no legitimate non-discriminatory reason for their disparate treatment of each plaintiff when compared to the identified similarly situated black comparator. As for the remaining three verdicts, Defendants presented either patently illogical rationales for their disparate treatment of each plaintiff, or the evidence presented by the Plaintiffs was clearly sufficient to support the jury’s conclusion that the non-discriminatory rationale given by Defendants was pretextual. While we are honestly troubled by the district court’s erroneous admission of irrelevant statistical evidence, we conclude that in light of both the curative effect of the given jury instructions and the one-sidedness of the evidence presented on those claims whose verdicts we uphold, Defendants did not suffer substantial injustice as a result of the court’s evidentia-ry ruling. Accordingly, we decline to reverse on these grounds. The Defendants also challenge the district court’s rulings on the admissibility of non-statistical evidence offered to establish “custom” under section 1983. Specifically, Defendants challenge the district court’s admission of testimony from Sam Brownlee, former County Manager of Fulton County from 1972-1990, and Alice Smith, former Clerk to the Board of Commissioners who left her position before Sheriff Barrett was elected. Brownlee testified as to four principal points. First, between 1978 and 1989 the Board of Commissioners engaged in public and private discussions about making a deliberate effort to increase minority hiring. Second, the dialogue regarding affirmative action increased in the 1980’s when five of the seven members of the Board of Commissioners were black. Third, during Brown-lee’s time as County Manager, several commissioners told him they believed there were too few blacks at department head level jobs and that he should recommend only the appointment of minorities to these positions until the situation was improved. Finally, in the mid-to-late 1980’s outside groups supposedly pressured the County Commission and others within Fulton County government to fill all appointments of any consequence with blacks. Alice Smith testified that Michael Hightower, a black Commissioner, told her she had to be replaced as Clerk with a black individual. Defendants correctly argue that the admitted testimony is not sufficiently connected in time or subject-matter to the challenged personnel decisions to be admissible. Brownlee’s testimony is completely unrelated to Sheriff Barrett’s actions. His testimony stemmed back twenty years before Sheriff Barrett was even elected. Second, the composition of the Board changed between Brownlee’s tenure with the Board and Sheriff Barrett’s election. Third, there is no evidence that the County did anything to suggest that Sheriff Barrett engage in discrimination, let alone that it influenced or coerced her to do so. Smith’s testimony is similarly irrelevant to the question of whether Sheriff Barrett discriminated against Plaintiffs. Smith’s testimony did not pertain to actions by any Sheriffs Department employee. Moreover, the testimony related to a time period nine years prior to Sheriff Barrett’s election. Although the non-statistical evidence at issue was improperly admitted by the district court, we again conclude its admission did not result in a substantial injustice to Defendants. First, because the anecdotal evidence admitted was so completely unconnected to the question of Sheriff Barrett’s discriminatory employment policies, and so unrelated