C.W., et al. v. Nevada Department of Education, et al.

CourtDistrict Court, D. Nevada
DecidedApril 17, 2026
Docket2:24-cv-01800
StatusUnknown

This text of C.W., et al. v. Nevada Department of Education, et al. (C.W., et al. v. Nevada Department of Education, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
C.W., et al. v. Nevada Department of Education, et al., (D. Nev. 2026).

Opinion

2 UNITED STATES DISTRICT COURT 3 DISTRICT OF NEVADA 4 * * * 5 C.W., et al., Case No. 2:24-cv-01800-GMN-DJA 6 Plaintiffs, 7 Order v. 8 Nevada Department of Education, et al., 9 Defendants. 10 11 Plaintiffs—schoolchildren and their parents—sue the Clark County School District, 12 among other institutional defendants, for injunctive and declaratory relief, alleging that CCSD has 13 not complied with its obligations to accommodate students with disabilities. Plaintiffs now move 14 for sanctions to address CCSD’s conduct in discovery, or in the alternative, to compel CCSD to 15 comply with its discovery obligations. (ECF No. 111). Plaintiffs also move to extend the joint 16 pretrial order deadline. (ECF No. 132). 17 The Court grants in part and denies in part Plaintiffs’ motion for sanctions. Plaintiffs refer 18 to broad categories of discovery conduct for which they believe CCSD should be sanctioned. But 19 Plaintiffs do not point out which specific rules CCSD has violated, which specific rules or sources 20 provide the Court’s authority to sanction CCSD for its violations, or the specific sanctions 21 Plaintiffs seek to address each asserted violation. So, while Plaintiffs may be frustrated with the 22 way CCSD has engaged in discovery, the Court cannot grant Plaintiffs any of the sanctions they 23 seek except for monetary sanctions related to a noticed deposition for which CCSD failed to 24 produce a witness. The Court will require the parties to meet and confer and attempt to stipulate 25 to the amount of those sanctions. The Court grants Plaintiffs’ motion to extend the joint pretrial 26 order deadline because they have shown good cause and excusable neglect and because no party 27 has opposed the motion. 1 I. Discussion. 2 A. Plaintiffs’ motion for discovery sanctions. 3 In their motion, Plaintiffs refer broadly and interchangeably to the Court’s inherent 4 authority to issue sanctions and its authority under Federal Rule of Civil Procedure 37. Relying 5 on these broad invocations of authority, Plaintiffs ask the Court to impose wide ranging sanctions 6 on CCSD, including precluding CCSD from offering certain defenses, compelling CCSD to 7 “make a full and complete discovery production,” and ordering CCSD to pay certain of Plaintiffs’ 8 witness and attorney’s fees. But Rule 37 and the Court’s inherent authority are not 9 interchangeable. And the various types of sanctions and scenarios under which they are 10 warranted in Rule 37 cannot be invoked in broad terms. As explained in more detail below, 11 Plaintiffs’ failure to identify the precise rule that CCSD violated, the source of the Court’s 12 authority to sanction CCSD for that precise violation, and the precise sanction Plaintiffs seek to 13 remedy each violation is fatal to the Court’s ability to analyze their motion. So, although CCSD’s 14 response is less than fulsome, the Court denies nearly all of Plaintiffs’ sanctions requests on their 15 face, except for one. The Court will proceed through its analysis of Plaintiffs’ motion by 16 addressing CCSD’s alleged discovery violations, going violation by violation. 17 1. CCSD’s late initial disclosures. 18 Plaintiffs argue that CCSD missed the parties’ agreed upon initial disclosure deadline in 19 March of 2025 by about two weeks due to issues with mailing and emailing the documents. (ECF 20 No. 111 at 5-6). Plaintiffs do not identify the rule that they claim CCSD has violated, the rule 21 governing their sanction request related to CCSD’s failure to meet the deadline, or what sanctions 22 they believe to be appropriate to address the failure. This argument is therefore not fully 23 developed. See Kor Media Grp., LLC v. Green, 294 F.R.D. 579, 582 n.3 (D. Nev. 2013) 24 (explaining that Courts only address well developed arguments) 25 Nonetheless, it appears that CCSD has violated Rule 26(a)(1)(C), which provides that a 26 party must make initial disclosures by either fourteen days after the parties’ Rule 26(f) conference 27 or by a time set through stipulation or court order. Rule 37(c)(1) is the rule governing this 1 26(a) or (e), “the party is not allowed to use that information or witness to supply evidence on a 2 motion, at a hearing, or at a trial, unless the failure was substantially justified or is harmless.” “In 3 addition to or instead of this sanction,” the Court may also order payment of reasonable expenses 4 and fees caused by the failure, inform the jury of the failure, or impose other appropriate 5 sanctions outlined in Rule 37(b)(2)(A)(i)-(vi). 6 However, Plaintiffs have identified no concrete1 harm arising out of the fact that CCSD 7 was almost two weeks late in providing its initial disclosures. Without more, the Court finds that 8 CCSD’s violation of Rule 26(a) was harmless under Rule 37(c)(1) and declines to issue any of the 9 sanctions outlined in Rule 37(c)(1) or Rule 37(b)(2)(A)(i)-(vi) to address it. The Court therefore 10 denies Plaintiffs’ motion to the extent it requests that the Court impose sanctions related to 11 CCSD’s late initial disclosures. 12 2. CCSD’s deficient initial and supplemental disclosures. 13 Plaintiffs assert that CCSD’s initial disclosures were “facially deficient,” and that CCSD’s 14 supplemental disclosures were also “materially deficient.” (ECF No. 111 at 6). Plaintiffs do not 15 explain how or why CCSD’s initial and supplemental disclosures were deficient. They also again 16 fail to identify the rule that CCSD violated, the rule governing their sanction request related to 17 CCSD’s deficient initial and supplemental disclosures, or what sanctions they believe to be 18 appropriate to address the deficiencies. This issue is therefore not fully developed. See Kor 19 Media Grp, 294 F.R.D. at 582 n.3. 20 Without more, even if the Court were to consider the issue under the appropriate rules— 21 Rule 26(a) and (e) and Rule 37(c)(1)—the Court cannot conduct an adequate analysis. The Court 22 therefore denies Plaintiffs’ motion to the extent it requests that the Court impose sanctions related 23 to CCSD’s deficient initial and supplemental disclosures. 24 25 1 Plaintiffs do refer generally to the harm that any delay in this litigation causes given the alleged 26 ongoing failures of CCSD to provide appropriate education to its students. While the Court 27 recognizes the importance of the issues alleged in this litigation, it cannot find that a delay of resolution on the merits in this case is, alone, a sufficiently concrete harm to warrant the extreme 3. CCSD’s failure to respond to Plaintiffs’ March 7, 2025, requests for 1 production. 2 3 Plaintiffs argue that CCSD has “failed to produce documents in response to document 4 requests that it has possessed since March 7, 2025…” (ECF No. 111 at 7). Plaintiffs claim that 5 CCSD waited until August 1, 2025, to ask Plaintiffs to provide “search terms for electronic 6 discovery,” presumably in aid of CCSD’s responses to some or all of the requests for production 7 at issue. (Id.). In a series of exchanges spanning August 1, 2025, until September 30, 2025, 8 which exchanges the Court will not detail here, Plaintiffs claim that they worked diligently with 9 CCSD to narrow the search terms and universe of documents. (Id. at 7-9). Plaintiffs assert that 10 CCSD delayed the process, misrepresented its capabilities in searching and gathering the 11 documents, and ultimately provided a spreadsheet of search term “hits” that was unhelpful to 12 determining which documents might be responsive to Plaintiffs’ requests for production. (Id.). 13 As before, Plaintiffs fail to identify the rule that CCSD violated, the rule governing their 14 sanction request related to CCSD’s failures to respond to requests for production, or what 15 sanctions they believe to be appropriate to address those failures.

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C.W., et al. v. Nevada Department of Education, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/cw-et-al-v-nevada-department-of-education-et-al-nvd-2026.