Chatman v. Ervin

CourtDistrict Court, District of Columbia
DecidedMarch 11, 2020
DocketCivil Action No. 2017-1826
StatusPublished

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

Bluebook
Chatman v. Ervin, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

NADINE CHATMAN,

Plaintiff, v. Civil Action No. 17-1826 (JEB) SONNY PURDUE, Secretary, United States Department of Agriculture,

Defendant.

MEMORANDUM OPINION

Plaintiff Nadine M. Chatman filed this pro se suit on September 7, 2017, against the

United States Department of Agriculture, alleging that USDA had engaged in numerous

discriminatory practices based on her race, age, gender, and filing of complaints with her Equal

Employment Opportunity office. Chatman alleges that this behavior violated Title VII of the

Civil Rights Act of 1964 and the Age Discrimination in Employment Act. As this litigation has

progressed, she believes that Defendant has not been sufficiently forthcoming in its discovery

responses. She thus now moves to compel. As most of her requests exceed what is relevant or

permissible, the Court will largely deny her Motion.

I. Background

Chatman, a black woman born in 1954, began working at USDA in October 2011 as a

temporary employee with a term not to exceed four years. See ECF No. 17 (Def. Answer) at 1,

4; ECF No. 15 (Am. Compl.) at 1. Her first assignment was as a Program Specialist in the Equal

Employment Opportunity Conflict Office. See Am. Compl. at 2; Def. Answer at 1. She was

subsequently reassigned to the Corporate Services Division in the Office of the Assistant

1 Secretary for Civil Rights (OASCR), where she remained until the end of her tenure in

September 2015. Id. In this role, Plaintiff provided aggrieved individuals with information

about their rights and obligations under equal-employment laws, gathered data on complaints,

and possessed the authority to attempt an informal resolution between the individuals and

agency. Id.; see U.S. Equal Emp’t Opportunity Comm’n, Equal Employment Opportunity Pre-

Complaint Processing, (Feb. 20, 2020), https://www.eeoc.gov. While she enjoyed her position at

USDA and hoped to continue, her work environment became increasingly hostile.

Chatman alleges that harsh treatment began in 2013, when her initial first-level

supervisor, Barbara Moore, implied that she was mentally disabled, reminded her constantly of

upper management’s watchful eye, implemented intimidation tactics by demanding that Plaintiff

use teleworking privileges that Moore knew had been suspended, and falsely accused her of

stealing work documents. See Am. Compl. at 3–4, 6. Sometime in 2014, after she filed a

complaint with the agency’s Office of Special Counsel and was named as a witness in two prior

EEO complaints against Moore, she was treated more severely. Id. For example, Chatman

indicated that in November of 2014, which was a few months after her OSC filing, her

performance-review rating was suddenly adjusted from “Outstanding” to the lower level of

“Superior.” Id. at 21.

While Plaintiff lists other interactions where she felt targeted, she alleges that her

improper treatment escalated when she discovered the sexual harassment and intimate

relationships that existed amongst her supervisors and co-workers. Id. at 22–23. Although she

gives no specification of when this occurred, Chatman contends that her in-depth knowledge of

these secret interactions not only led to the “unexplainable promotion” of others but also resulted

in retaliatory tactics from her supervisors. Id. at 20, 22–24. On one occasion, Chatman

2 recounted, her subsequent first-level supervisor, Candice Glover, gave a position to an allegedly

unqualified candidate instead of selecting Plaintiff for permanent employment. Id. at 24. She

also alleges that her fourth-level supervisor, Joe Leonard, unfairly accused her of stealing files

and favored applicants who he felt could satisfy his sexual desires. Id. at 10–11, 22, 24. Last,

Chatman alleges that in addition to being ostracized for her awareness of the aforementioned

behavior, she was not considered for other positions within USDA because of her age and race.

Id. at 20.

On September 6, 2019, Plaintiff sent Interrogatories and Requests for Production and

Admission to Defendant. See ECF No. 29 (Def. Opp. to Pl. Mot. Compel) at 1. On November

6, at the conclusion of a status conference, the parties met to determine which responses were

still outstanding; however, they were unable to come to an agreement regarding which materials

were relevant for Plaintiff’s case. Id. at 2. The Court thus permitted Plaintiff to file this Motion

to Compel.

II. Legal Standard

Federal Rule of Civil Procedure 26(b)(1) permits “discovery regarding any nonprivileged

matter that is relevant to any party’s claim or defense and proportional to the needs of the case.”

Information is relevant when it “bears on, [or could reasonably] lead to other matter that could

bear on, any issue that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S.

340, 351 (1978). The Federal Rules and this Court encourage the exchange of information

through good-faith discovery and communication, but, while discovery is broadly allowed, it is

not limitless. Under Federal Rule 26(b)(2)(C)(iii), the Court “may limit discovery on its own

initiative, if it determines that the burden or expense of the proposed discovery outweighs its

likely benefit, [when] taking into account the needs of the case, the amount in controversy, the

3 parties’ resources, the importance of the issue at stake in the litigation, and the importance of the

proposed discovery in resolving those issues.” Meijer, Inc. v. Warner Chilcott Holdings Co., III.,

Ltd., 245 F.R.D. 26, 30 (D.D.C. 2007) (quotation marks omitted).

III. Analysis

The parties have not been able to resolve their differences regarding fourteen

interrogatories and twenty-five document requests. Chatman contends that all her inquiries are

pertinent to her claims under the ADEA and Title VII. See ECF No. 30 (Pl. Resp.) at 1.

Defendant, however, asserts that while Plaintiff alleges that she was “subjected to discrimination

on the basis of color, race, age, gender and/or retaliation[,] . . . the majority of [her]

Interrogatories and Requests for Production are not” related to her specific discrimination claims.

See Def. Opp. at 1. USDA contends that the information sought is “overly broad and not

reasonably calculated to lead to the discovery of admissible evidence.” Id. The Court has

thoroughly examined all of the discovery requests and objections, and it considers them in

groups according to subject matter. It does so while noting its difficulty in clearly categorizing

Plaintiff’s interrogatories and document requests, as each contained numerous questions veering

in different directions.

The first group of interrogatories and document requests seek a variety of material ––

generally human-resource records –– regarding entire USDA departments as well as groups of

individual employees who are not relevant to Plaintiff’s claims. Interrogatory Nos. 19, 23, 28,

29, and 30 and Document Request Nos. 1, 8, 12, 16, and 18, for the most part, cast too wide a net

by demanding an extensive amount of information not in any way related to Plaintiff’s

discrimination claims. Document Request No. 8, for example, seeks all EEO Complaints filed

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Related

Oppenheimer Fund, Inc. v. Sanders
437 U.S. 340 (Supreme Court, 1978)
Meijer, Inc. V. Warner Chilcott Holdings Co.
245 F.R.D. 26 (D.C. Circuit, 2007)

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