Acosta v. Williamson Cnty.
| Docket Number | 1:21-cv-00615-DII |
| Decision Date | 06 June 2023 |
| Parties | BERNARDO ACOSTA, Plaintiff v. WILLIAMSON COUNTY, TEXAS and ALYSSA HOFFMAN, Defendants |
| Court | U.S. District Court — Western District of Texas |
Now before the Court are Plaintiff's Motion for Production Against Defendant Williamson County, Texas, for Documents Related to Prior Settlement Agreements, filed April 12, 2023 (Dkt. 109), and Defendant Williamson County's Response filed April 19, 2023 (Dkt. 111).[1]
I. Background
Plaintiff Bernardo Acosta filed this suit against Williamson County Texas and several individual defendants, including Williamson County Jail Officer Alyssa Hoffman, after his left ring finger was broken at the jail following his arrest for the offense of driving while intoxicated on May 27, 2021. Acosta alleges that he notified jailers he suffered from psychiatric and sleep disorders but was refused required medical treatment. In his Second Amended Complaint, Acosta asserted claims against all defendants for excessive force under the Fourth, Eighth, and Fourteenth Amendments, as well as state-law claims for negligence and gross negligence; claims against the County for discrimination, deliberate indifference to medical care under the Due Process Clause of the Fourteenth Amendment, and failure to accommodate under the Americans with Disabilities Act (“ADA”) and the Rehabilitation Act; and state-law claims for assault and battery against the individual defendants. Dkt. 34.
The defendants moved to dismiss. The District Court adopted this Court's Report and Recommendation and dismissed all of Acosta's claims except his ADA, Rehabilitation Act, and negligence claims alleged against the County, and his claims of excessive force and assault and battery alleged against Hoffman. Dkt. 79. Jury trial is set for October 2023. Dkt 72.
In the latest of the parties' discovery disputes, Acosta moves to compel production of all settlement agreements involving claims of excessive force into which the County has entered since January 1, 2015. The County argues that this discovery is outside the scope of Rule 26 because prior settlements agreements “are unrelated and irrelevant to this case.” Dkt. 111 at 2.
II. Legal Standards
Rule 26(b)(1) provides:
Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.
While the scope of discovery generally is broad, “discovery, like all matters of procedure, has ultimate and necessary boundaries.” Hickman v. Taylor, 329 U.S. 495, 507 (1947). Rule 26(b)(2)(C) mandates that the Court limit the frequency or extent of discovery otherwise allowed if it determines that “(i) the discovery sought is unreasonably cumulative or duplicative, or can be obtained from some other source that is more convenient, less burdensome, or less expensive; (ii) the party seeking discovery has had ample opportunity to obtain the information by discovery in the action; or (iii) the proposed discovery is outside the scope of Rule 26(b)(1).”
After a party has attempted in good faith to obtain discovery without court action, that party may move for an order compelling disclosure or discovery. Fed.R.Civ.P. 37(a). The moving party bears the burden to show that the materials and information sought are relevant to the action or will lead to the discovery of admissible evidence. Earl v. Boeing Co., 515 F.Supp.3d 590, 599 (E.D. Tex. 2021); Camoco, LLC v. Leyva, 333 F.R.D. 603, 606 (W.D. Tex. 2019). Once the moving party establishes that the materials requested fall within the scope of discovery, the burden shifts to the nonmovant to show “how the requested discovery is overly broad, unduly burdensome, or oppressive by submitting affidavits or offering evidence revealing the nature of the burden.” Lopez v. Don Herring Ltd., 327 F.R.D. 567, 580 (N.D. Tex. 2018).
“The Court must balance the need for discovery by the requesting party and the relevance of the discovery to the case against the harm, prejudice, or burden to the other party.” Cmedia, LLC v. LifeKey Healthcare, LLC, 216 F.R.D. 387, 389 (N.D. Tex. 2003) (quoting Truswal Sys. Corp. v. Hydro-Air Eng'g, Inc., 813 F.2d 1207, 1210 (Fed. Cir. 1987)). A trial court enjoys wide discretion in determining the scope and effect of discovery. Equal Emp. Opportunity Comm'n v. BDO USA, L.L.P., 876 F.3d 690, 698 (5th Cir. 2017).
III. Analysis
Acosta moves to compel the County to produce the following documents:
Dkt. 109-2 at 7-9. The County objected that each request is “overbroad, not reasonably limited in time or scope, not proportional to the needs of the case, constitutes an impermissible and speculative fishing expedition, and is not reasonably calculated to lead to the discovery of relevant or admissible evidence.” Id. (citation omitted).
A discovery request is relevant when the request seeks admissible evidence or is reasonably calculated to lead to the discovery of admissible evidence. Crosby v. Louisiana Health Serv. & Indem. Co., 647 F.3d 258, 262 (5th Cir. 2011). “Although under Federal...
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