Belafon Aradon v. Snohomish County

CourtDistrict Court, W.D. Washington
DecidedJanuary 11, 2023
Docket2:20-cv-01665
StatusUnknown

This text of Belafon Aradon v. Snohomish County (Belafon Aradon v. Snohomish County) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Belafon Aradon v. Snohomish County, (W.D. Wash. 2023).

Opinion

1 2 3 4

5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 NYLYSHA STARVION BELAFON ARADON, et al., CASE NO. 2:20-CV-1665-RSM-DWC 11 Plaintiff, ORDER RE PLAINTIFFS’ MOTION 12 FOR SANCTIONS v. 13 SNOHOMISH COUNTY, et al., 14 Defendant. 15

The District Court has referred this action, filed pursuant to 42 U.S.C. § 1983, to United 16 States Magistrate Judge David W. Christel. Presently before the Court is Plaintiffs’ Renewed 17 Motion Pursuant to Federal Rule of Civil Procedure 37(e) for Sanctions Against Defendants 18 Susan Walker and Snohomish County1 for Spoliation of Evidence. Dkt. 186. 19 The Court notes that additional motions remain pending and will be addressed 20 separately. See, Dkts. 182, 188, 191, 192. 21

22 23 24 1 Defendants Kirsten Haugen and Sara Di Vittorio are not implicated in this motion. 1 BACKGROUND 2 On October 13, 2022 Plaintiffs filed a renewed motion for sanctions against Defendants 3 Susan Walker (Defendant Walker) and Snohomish County for spoliation of evidence. Dkt. 186. 4 On October 31, 2022 Defendants filed their responses. Dkts. 209, 212. On November 4, 2022

5 Plaintiffs filed a reply. Dkt. 214. 6 The Court incorporates the facts of this case as set forth in its previous orders. See e.g., 7 Dkt. 77. 8 Plaintiffs allege Defendant Walker and Snohomish County destroyed and/or lost evidence 9 relevant to this case during the state court dependency and termination proceedings involving 10 minor Plaintiff A.H. (the dependency case), which took place in Snohomish County Superior 11 Court between 2013 and 2016. 12 Defendant Walker and Snohomish County insist Plaintiffs’ reliance on evidentiary issues 13 that arose in the dependency case is misplaced, and that in this case they have met their 14 preservation and production obligations by producing the entire archived file that existed at the

15 time Plaintiffs filed a tort claim notice in 2020. 16 EVIDENTIARY OBJECTIONS 17 Defendants assert Plaintiffs have no admissible evidence showing they destroyed 18 evidence. Dkt. 209 at 6. Plaintiffs rely on the findings and memorandum decision entered by 19 Snohomish County Superior Court Judge Anita Farris (Judge Farris) explaining her reasons for 20 recusing herself from the dependency case following the termination trial and dozens of post- 21 trial hearings that followed the revelation of Volunteer Guardian ad Litem Program (VGAL 22 Program) misconduct (the Farris memo). See, Dkts. 37-2 through 37-9. Defendants contend 23 Plaintiffs’ reliance on the Farris memo is improper because it constitutes hearsay and because it

24 1 is irrelevant as it does “not relate to the discovery that was produced in this case.” Id. at 6-7. The 2 Court disagrees with Defendants on both counts, for the limited purposes of this motion.2 3 Case law indicates the Federal Rules of Evidence do not necessarily apply in the context 4 of a motion for sanctions. See, Deerpoint Grp., Inc. v. Agrigenix, LLC, Case No.1:18-cv-00536-

5 AWI-BAM, 2022 WL 16551632, at *10 (E.D. Cal. Oct. 31, 2022). Additionally, other pretrial, 6 non-dispositive motions do not require that evidence be submitted in a form that would be 7 admissible at trial. See e.g., AtPac, Inc. v. Aptitude Sols., Inc., Case No. CIV. 2:10-294 WBS 8 JFM, 2011 WL 13242817, at *1 (E.D. Cal. Apr. 13, 2011). However, “‘evidence relied upon 9 must, at a minimum, bear indicia of reliability.’” Id. at *1 (quoting Sentis Grp., Inc., Coral Grp., 10 Inc. v. Shell Oil Co., 559 F.3d 888, 901 (8th Cir. 2009)); see also, Juul Labs, Inc. v. Chou, Case 11 No. 2:21-cv-03056-DSF-PDx, 2022 WL 2161063, at *6 (C.D. Cal. May 6, 2022) (accepting 12 evidence that bears sufficient indicia of reliability in a sanctions motion). 13 Here, the Farris memo bears a sufficient indicia of reliability. Judge Farris presided over 14 the state court dependency action and following her verbal termination of parental rights she

15 conducted evidentiary hearings regarding alleged misconduct by Defendant Walker, the VGAL 16 program, and others. Dkt. 125. Moreover, the state court of appeals found Judge Farris’s findings 17 reliable when determining Plaintiffs’ due process rights were violated during the termination 18 hearing. See, Matter of Dependency of A.E.T.H., 9 Wash. App. 2d 502, 520 (2019). 19 The Court concludes Judge Farris’s findings are sufficiently reliable to be considered in 20 ruling on the motion for sanctions. 21 22

23 2 Defendants also assert the Farris memo is not relevant to the issue of whether evidence was destroyed in 24 this case. The Court finds this argument goes to the weight of the Farris memo, not the admissibility. 1 DISCUSSION 2 Plaintiffs allege Defendant Walker hid, altered, and deleted email evidence of 3 inappropriate contact between her supervisee—non-party VGAL Denice Brook (VGAL 4 Brook)3—and non-party foster mother J.B., including the unauthorized use of home computers

5 and personal cell phones. Dkt. 186 at 3. In addition, Plaintiffs allege that during the dependency 6 case Defendants hid or destroyed “an entire box of [VGAL] Brook’s hard copy files on the 7 dependency action”. Dkt. 186 at 3. Thus, the evidence at issue in this motion involves both 8 electronically stored information (ESI) and a box containing VGAL Brook’s personal files (the 9 Brook Box). 10 Defendants insist they have met their preservation and production obligations in this case 11 by producing the entire archived file as it existed at the conclusion of the dependency case. See 12 generally, Dkts. 209, 212. Defendant Walker additionally argues, “The time and place to bring 13 such a motion was during the litigation of the Snohomish County dependency.” Dkt. 209 at 2. 14 Snohomish County concurs with Defendant Walker, and further contends that discovery issues in

15 this case cannot be remedied by Fed. R. Civ. P. 37 because the rule “does not provide a 16 mechanism for the Court to grant substantive relief based on alleged misconduct that occurred in 17 a separate, state law proceeding.” Dkt. 212 at 10. 18 Plaintiffs reply that Defendants had a duty to preserve the allegedly spoliated evidence at 19 the time is was destroyed—likely between 2013 and 2016—while the dependency case was 20 active in Snohomish County Superior Court, and also in anticipation of future civil litigation. 21 Dkt. 214. 22 23

24 3 VGAL Brook passed away unexpectedly in January 2015. 1 While the legal standards applicable to ESI and paper files are similar—each requiring 2 Plaintiff to make a threshold showing that the information at issue was irreversibly lost or 3 destroyed—the Court will analyze them separately, beginning with the paper documents 4 allegedly contained in the Brook Box.

5 I. The Brook Box 6 a. Legal Standard 7 Spoliation is the “destruction or significant alteration of evidence, or the failure to 8 preserve property for another’s use as evidence, in pending or future litigation.” Kearney v. 9 Foley & Lardner, LLP, 590 F.3d 638, 649 (9th Cir. 2009) (internal citation omitted). Pursuant to 10 its inherent powers to control the litigation before it, the district court may levy sanctions, 11 including the entry of judgment, for spoliation of evidence. U.S. v. $40,955.00 in U.S.

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Belafon Aradon v. Snohomish County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/belafon-aradon-v-snohomish-county-wawd-2023.