Brown v. Dunn

CourtDistrict Court, M.D. Alabama
DecidedOctober 4, 2021
Docket2:21-cv-00440
StatusUnknown

This text of Brown v. Dunn (Brown v. Dunn) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Dunn, (M.D. Ala. 2021).

Opinion

IN THE DISTRICT COURT OF THE UNITED STATES FOR THE

MIDDLE DISTRICT OF ALABAMA, NORTHERN DIVISION

JENNIFER BROWN, ) Administratrix for the ) Estate of Larry Brown, ) deceased, ) ) Plaintiff, ) ) CIVIL ACTION NO. v. ) 2:21cv440-MHT ) (WO) JEFFERSON S. DUNN, Alabama ) Prison Commissioner; ) et al., ) ) Defendants. )

OPINION AND ORDER

This case comes before the court on plaintiff Jennifer Brown’s renewed motion for leave to conduct expedited discovery. The motion will be denied. Brown, as the administrator of the estate of decedent Larry Brown, brought claims against defendants Jefferson Dunn, Patricia Jones, and David Lamar under 42 U.S.C. § 1983 and Alabama law for their alleged roles in the decedent’s death while incarcerated at the Bullock Correctional Facility. Administrator Brown brought a motion for leave to conduct expedited discovery, pursuant to Federal Rules of Civil Procedure

26(d)(1) and 30(a)(2)(iii). Pl.’s Mot. for Leave to Conduct Expedited Discovery (Doc. 10). That motion was denied. Brown now renews her motion for leave to conduct expedited discovery and requests that the court

(1) permit her to depose ten identified inmates at the Correctional Facility; (2) order the defendants to produce any investigation information or reports in their possession, including any reports identifying

witnesses to the alleged attack or attacks on decedent; and (3) permit her to depose further witnesses who may become known to her based on the materials provided by

the defendants.1 Pl.’s Renewed Mot. for Leave to

1. In her first motion, administrator Brown requested leave to depose defendants Jones and Lamar. While her renewed motion repeats a paragraph about the need for Jones and Lamar’s testimony, Pl.’s Renewed Mot. for Leave to Conduct Expedited Discovery (Doc. 19) at 2, she has titled her motion “Plaintiff’s Renewed Motion for Leave to Conduct Expedited Discovery of Incarcerated Eye-Witnesses,” and her request for relief omits Jones and Lamar. Pl.’s Renewed Mot. for 2 Conduct Expedited Discovery (Doc. 19). The defendants have filed motions to dismiss on the basis of qualified

immunity, among other grounds. Federal Rule of Civil Procedure 26(d)(1) states the general rule that, “A party may not seek discovery from any source before the parties have conferred as

required by Rule 26(f), except ... when authorized by these rules, by stipulation, or by court order.” Fed. R. Civ. P. 26(d)(1). Administrator Brown moves for a court order authorizing expedited discovery. Although

the Eleventh Circuit Court of Appeals “has not adopted a standard for allowing expedited discovery, ... many district courts within the Eleventh Circuit have

expressly used a general good cause standard when confronted with expedited discovery requests.” , No. 1:20-CV-03210-SCJ, 2020 WL 8258735, at

Leave to Conduct Expedited Discovery (Doc. 19) at 4. Consequently, the court concludes that the paragraph related to Jones and Lamar was included accidentally and that Brown has not renewed her request to depose those defendants. 3 *3 (N.D. Ga. 2020) (Jones, J.). Under this standard, “the party requesting expedited discovery has the

burden of showing the existence of good cause, and that the need for the discovery outweighs any prejudice to the opposing party.” , No. 08-01916-MD-MARRA, 2015 WL 12601043, at *3

(S.D. Fla. 2015) (Marra, J.). “Good cause may be established by showing ‘some impelling urgency which necessitates action forthwith and excuses giving notice to the other party,’ such as ‘a showing that the

desired testimony is in hazard of loss unless the deposition is taken forthwith.’” , No. 09-23864-CIV, 2010

WL 1027408, at *1 (S.D. Fla. 2010) (Seitz, J.) (quoting , 279 F. Supp. 422, 423–24 (S.D.N.Y. 1968) (MacMahon, J.)). Resolution of administrator Brown’s motion for

expedited discovery must take into account the defendants’ motions to dismiss on the basis of

4 qualified immunity. When a defendant has asserted an immunity defense, “[t]he court starts from the general

premise that ‘until the threshold immunity question is resolved, discovery should not be allowed.’” , 209 F.R.D. 493, 495 (M.D. Ala. 2002) (Thompson, J.) (quoting

, 457 U.S. 800, 818 (1982)); , 861 F.3d 1300, 1302 (11th Cir. 2017) (per curiam) (“[I]mmunity is a right not to be subjected to litigation beyond the point at which

immunity is asserted.”). Although “[d]istrict judges are accorded wide discretion in ruling upon discovery motions,” , 97 F.3d 499, 506 (11th

Cir. 1996), “the trial court must exercise its discretion in a way that protects the substance of the qualified immunity defense. It must exercise its discretion so that officials are not subjected to

unnecessary and burdensome discovery or trial

5 proceedings,” , 523 U.S. 574, 597–98 (1998).

A defendant’s entitlement to avoid the burden of discovery is particularly substantial where the defendant has asserted immunity in a motion to dismiss that challenges the legal sufficiency of the complaint.

, 472 U.S. 511, 526 (1985) (“Unless the plaintiff’s allegations state a claim of violation of clearly established law, a defendant pleading qualified immunity is entitled to dismissal

before the commencement of discovery.”); , No. 2:18-CV-977-WKW, 2019 WL 1233853, at *2 (M.D. Ala. 2019) (Watkins, J.) (observing that “the

court should not allow discovery in the face of a pending motion to dismiss that tests the legal sufficiency of the complaint — especially when that motion also asserts an immunity defense”). When such a

motion is pending, the plaintiff’s need for the discovery is limited because such challenges present

6 “no issues of fact,” as “the allegations contained in the pleading are presumed to be true.”

, 123 F.3d 1353, 1367 (11th Cir. 1997).2

2. As support for her discovery request, administrator Brown cites primarily to cases in which a court concluded that limited discovery was appropriate in order for the court to rule on a qualified-immunity defense asserted in a motion for summary judgment, rather than a motion to dismiss. , 523 U.S. at 593 n.14 (recognizing that “limited discovery may sometimes be necessary before the district court can resolve a motion for summary judgment based on qualified immunity”). These cases do not support Brown’s request for expedited discovery prior to resolution of the defendants’ motions to dismiss.

In one case, , No. 5:13-CV-256 (MTT), 2014 WL 2565579 (M.D. Ga. 2014) (Treadwell, J.), a district court ordered “limited discovery” prior to resolution of a motion to dismiss on the ground of qualified immunity. In that case, the plaintiff administrator of the estate of an inmate who was killed by his cellmate brought § 1983 claims against prison employees, who moved for dismissal on the ground of qualified immunity and failure to state a claim.

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