Brian Horsley v. KBP Investments

CourtCourt of Appeals for the Fourth Circuit
DecidedJune 27, 2024
Docket22-2185
StatusUnpublished

This text of Brian Horsley v. KBP Investments (Brian Horsley v. KBP Investments) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brian Horsley v. KBP Investments, (4th Cir. 2024).

Opinion

USCA4 Appeal: 22-2185 Doc: 39 Filed: 06/27/2024 Pg: 1 of 6

UNPUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 22-2185

BRIAN HORSLEY,

Plaintiff - Appellant,

v.

KBP INVESTMENTS; FQSR, LLC, trading as KBP Foods,

Defendants - Appellees, and

GBENGA OLAGBAJU, KFC, General Manager,

Defendant.

Appeal from the United States District Court for the District of Maryland, at Greenbelt. Paula Xinis, District Judge. (8:20-cv-03241-PX)

Submitted: June 20, 2024 Decided: June 27, 2024

Before NIEMEYER, KING, and QUATTLEBAUM, Circuit Judges.

Affirmed by unpublished per curiam opinion.

Brian Horsley, Appellant Pro Se. James Randall Coffey, FISHER & PHILLIPS LLP, Kansas City, Missouri, for Appellees. USCA4 Appeal: 22-2185 Doc: 39 Filed: 06/27/2024 Pg: 2 of 6

Unpublished opinions are not binding precedent in this circuit.

2 USCA4 Appeal: 22-2185 Doc: 39 Filed: 06/27/2024 Pg: 3 of 6

PER CURIAM:

Brian Horsley filed an amended complaint against his former employer, FQSR, LLC

d/b/a KBP Foods (“KBP”), alleging that KBP failed to provide reasonable

accommodations for his disability and, instead, unlawfully terminated his employment due

to this disability or in retaliation for requesting reasonable accommodations, all in violation

of the Americans with Disabilities Act of 1990, 42 U.S.C. §§ 1202 to 12213, and the

Maryland Fair Employment Practices Act, Md. Code Ann., State Gov’t § 20-606 (2023).

KBP moved to dismiss the amended complaint as a sanction for Horsley’s failure to

respond to its discovery requests, appear for his deposition, and comply with the district

court’s orders. See Fed. R. Civ. P. 37(b)(2)(A)(v); Fed. R. Civ. P. 41(b). KBP also

requested compensation for the expenses it incurred due to Horsley’s failure to attend his

deposition. See Fed. R. Civ. P. 37(d)(3). The district court granted KBP’s motions,

ordering Horsley to pay $200 to compensate KBP for the cost of the court reporter and

dismissing the amended complaint. Horsley appeals that order and challenges several of

the court’s discovery-related rulings. We affirm.

“In reviewing a district court’s findings and discovery rulings, we are mindful of

the broad discretion accorded to district courts to supervise discovery, including the

imposition of sanctions for discovery abuses, as part of their case-management authority.”

Mey v. Phillips, 71 F.4th 203, 217 (4th Cir. 2023) (internal quotation marks omitted). And

because “[a] district court has wide latitude in controlling discovery,” “its rulings will not

be overturned absent a showing of clear abuse of discretion.” Id. (internal quotation marks

omitted). “A district court abuses its discretion when it acts arbitrarily or irrationally, fails

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to consider judicially recognized factors constraining its exercise of discretion, relies on

erroneous factual or legal premises, or commits an error of law.” United States v. Davis,

99 F.4th 647, 653 (4th Cir. 2024) (internal quotation marks omitted).

“If a party fails to obey an order to provide or permit discovery, fails to appear for

a deposition, or fails to serve a response after being served with interrogatories or a request

for production, the district court may order sanctions, including” dismissing the complaint.

Mey, 71 F.4th at 218; see Fed. R. Civ. P. 37(b)(2)(A)(v). But “[w]hen the sanction involved

is [dismissal], the district court’s range of discretion is more narrow because the district

court’s desire to enforce its discovery orders is confronted head-on by the party’s rights to

a trial by jury and a fair day in court.” Mey, 71 F.4th at 218 (internal quotation marks

omitted). Indeed, “only the most flagrant case, where the party’s noncompliance represents

bad faith and callous disregard for the authority of the district court and the Rules, [should]

result in the extreme sanction of dismissal.” Mut. Fed. Sav. & Loan Ass’n v. Richards &

Assocs., Inc., 872 F.2d 88, 92 (4th Cir. 1989).

To determine the propriety of dismissal as a sanction for discovery violations, the

court must consider: “(1) whether the noncomplying party acted in bad faith; (2) the

amount of prejudice his noncompliance caused his adversary; (3) the need for deterrence

of the particular sort of noncompliance; and (4) the effectiveness of less drastic sanctions.”

Mey, 71 F.4th at 218 (internal quotation marks omitted). Moreover, “a party is entitled to

be made aware of the drastic consequences of failing to meet the court’s conditions at the

time the conditions are imposed, when he still has the opportunity to satisfy the conditions

and avoid the sanction.” Id. (cleaned up).

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A district court also has the authority to dismiss an action for a party’s failure to

comply with its orders, and we review a court’s decision to dismiss on this ground for an

abuse of discretion. See Fed. R. Civ. P. 41(b); Atkisson v. Holder, 925 F.3d 606, 620, 625-

27 (4th Cir. 2019). “Given the inherent judicial authority to make such dismissals, a court

may, in appropriate circumstances, enter such a dismissal sua sponte, even absent advance

notice of the possibility of dismissal.” Atkisson, 925 F.3d at 625 (internal quotation marks

omitted). But “recognizing the severity of dismissal as a sanction,” we have “identified

four criteria that guide a district court’s discretion in dismissing a case under Rule 41(b).”

Id. Specifically, the court “should weigh: (1) the plaintiff’s degree of personal

responsibility; (2) the amount of prejudice caused the defendant; (3) the presence of a

drawn out history of deliberately proceeding in a dilatory fashion; and (4) the effectiveness

of sanctions less drastic than dismissal.” Id. (internal quotation marks omitted).

Limiting our review to the issues raised in Horsley’s informal brief, we discern no

abuse of discretion in the district court’s order granting KBP’s motions for sanctions. See

Jackson v. Lightsey, 775 F.3d 170, 177 (4th Cir. 2014) (“The informal brief is an important

document; under [4th Cir. R. 34(b)], our review is limited to issues preserved in that

brief.”). Specifically, the district court did not abuse its discretion in concluding that

Horsley acted in bad faith by failing to respond to KBP’s discovery requests, even after the

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Sharyl Attkisson v. Eric Holder, Jr.
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Diana Mey v. Judson Phillips
71 F.4th 203 (Fourth Circuit, 2023)
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99 F.4th 647 (Fourth Circuit, 2024)

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