Durfee v. GPEX Transport, Inc.

CourtDistrict Court, D. South Dakota
DecidedDecember 11, 2024
Docket4:23-cv-04042
StatusUnknown

This text of Durfee v. GPEX Transport, Inc. (Durfee v. GPEX Transport, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. South Dakota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Durfee v. GPEX Transport, Inc., (D.S.D. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA

SOUTHERN DIVISION

SHELBY KAY DURFEE, 4:23-CV-04042-KES Plaintiff, vs. ORDER ON DEFENDANTS’ MOTION TO COMPEL

DOCKET NO. 34 GPEX TRANSPORT, INC.; AMIT KUMAR, Defendants.

INTRODUCTION A discovery dispute is before the court on the complaint of South Dakota resident Shelby Kay Durfee against Canadian trucking firm GPEX Transport, Inc. and truck driver Amit Kumar. Docket Nos. 1 & 34. Ms. Durfee alleges various causes of action related to a March 25, 2021, highway collision. See generally Docket No. 1. Pursuant to Federal Rules of Civil Procedure 35 and 37, defendants move to compel Ms. Durfee’s attendance at independent medical examinations “in an unfettered and unrecorded manner.” Docket No. 34 at p. 1. Pursuant to 28 U.S.C. § 1332(a)(2), jurisdiction is premised on the parties’ diversity of citizenship. Docket No. 1, ¶ 8; Docket No. 10, ¶ 9. This opinion resolves defendants’ Motion to Compel Independent Medical Examinations [Docket No. 34], which the district court referred to this magistrate judge. Docket No. 42. FACTS

On or about March 25, 2021, at approximately 4:40 a.m., Amit Kumar was driving a tractor-trailer, owned by GPEX Transport, southbound on Interstate 29 in Lincoln County, South Dakota. Docket No. 1, ¶ 24. Kumar was driving in the left-hand passing lane. Id. ¶ 27. Shelby Kay Durfee claims she was driving a Ford Fusion in the right lane when Kumar entered her lane, causing a violent collision. Id. ¶¶ 28–34.

Ms. Durfee filed a complaint with this court alleging the negligence of both GPEX and Kumar. See generally Docket No. 1. Ms. Durfee alleges that she “suffered serious injuries affecting her activities of normal daily living” and that these injuries are believed to be permanent in nature. Id. ¶¶ 82, 90. During discovery, defendants noticed three independent medical

examinations for Ms. Durfee to attend, for “a neuropsych, neurologist and PM&R specialist.” See Docket Nos. 36-2, 36-3, 36-4; cf. Docket No. 36-6. The examinations were all to take place in the Twin Cities of Minneapolis and St. Paul, Minnesota, and on three different dates, despite Ms. Durfee being a resident of Sioux Falls, and none of the parties being a resident of Minnesota. Docket Nos. 36-2, 36-3, 36-4, see Docket No. 1, ¶¶ 1–2. Counsel for the parties compromised on cost reimbursements and examinations that took place on consecutive days. See generally Docket No. 36-5. What counsel could

not agree on, however, was whether the examinations must be video recorded. Id. Counsel for defendants presented what each of the proposed doctors stated they would allow:

Dr. Richard Doss – For recording the IME a court reporter must be scheduled to record the IME and only the interview portion of the exam may be recorded. Dr. Erin Carlson – will allow audio and video recording for the interview portion only. Dr. Jennifer Thomas – Dr. Jennifer Kendall Thomas – she will allow audio recording during the IME as long as she is allowed to take her own recording as well. You will need to arrange for a court reporter for those that allow stenographic recording and audio/video services at your own expense. We will also demand that you produce any video, audio, or stenographic recordings to us within one week of the exam. Video/audio recordings must be produced in native format. Id. at p. 3. This attempt at compromise was rejected by Ms. Durfee, who insisted on litigating the matter. Id. at p. 1. Defendants brought this motion, arguing Ms. Durfee has no basis to record her examinations. DISCUSSION Federal Rule of Civil Procedure 35(a)(1) provides that “[t]he court where the action is pending may order a party whose mental or physical condition . . . is in controversy to submit to a physical or mental examination by a suitably licensed or certified examiner.” The order “may be made only on motion for good cause and on notice to all parties and the person to be examined.” FED. R. CIV. P. 35(a)(2)(A). “A plaintiff in a negligence action who asserts mental or physical injury places that mental or physical injury clearly in controversy and provides the defendant with good cause for an examination to determine the existence and extent of such asserted injury.” Schlagenhauf v. Holder, 379 U.S. 104, 119 (1964).

Here, Ms. Durfee’s complaint is a negligence action that asserts mental or physical injury. See generally Docket No. 1. So, the question of her well- being is “clearly in controversy” and defendants’ motion is made for good cause. Schlagenhauf, 379 U.S. at 119. Ms. Durfee argues that defendants can use test data from her own testing, thus undermining good cause to seek their own. Docket No. 39 at p. 1. That theory conflicts with Schlagenhauf’s

unequivocal holding that pleadings such as Ms. Durfee’s provide per se good cause for a defendant to seek IMEs. She cannot ward off defendants’ examinations by winning a race to her preferred providers. Rule 35 also explains precisely what the party or person examined is entitled to upon request—“a copy of the examiner’s report,” which “must be in

writing and must set out in detail the examiner’s findings, including diagnoses, conclusions, and the results of any tests.” FED. R. CIV. P. 35(b)(1)–(2). Rule 35 does give courts broad discretion to fashion (or not) conditions under which examinations must be administered. Sanden v. Mayo Clinic, 495 F.2d 221, 225 (8th Cir. 1974); see FED. R. CIV. P. 35(a)(2)(B). But in the context of allowing a recording, most courts (including those in this district) discourage the practice absent a compelling reason. See, e.g., Tomlin v. Holecek, 150 F.R.D. 628, 631–34 (D. Minn. 1993); Holland v. United States, 182 F.R.D. 493, 495–96 (D.S.C. 1998) (collecting cases); Petersen v. Rapid City, Pierre & E. R., Inc., No. 5:22-CV-5064, 2023 WL 6466199, at *4–5 (D.S.D. Oct. 4, 2023) (collecting cases). Principles underlying this position include “preserv[ing] the equal footing of the parties,” ensuring the authenticity of the examination

results, and avoiding “the infusion of the adversary process” into what should be a purely scientific endeavor. Tomlin, 150 F.R.D. at 631–34. The requirement of a compelling reason for recording finds its basis in Rule 26. Petersen, 2023 WL 6466199, at *3–5. As the Petersen court explained, an IME is simply one method of discovery. Id. at *3. And so, once

relevance is established for an IME, it becomes the burden of the party resisting discovery “to show why the examination should not go forward in the manner noticed.” Id. at *3–4 (citations omitted). Here, Ms. Durfee argues that recording is necessary for two reasons: (1) to mitigate and evaluate the practice effect; and (2) to generally ensure the

defendants’ examiners “meticulously administer the requested examinations, comply with test parameters, and accurately report the results and [Ms. Durfee’s] performance.” Docket No. 39 at pp. 2, 17. Ms. Durfee explains that the “ ‘practice effect’ . . . refers to the improvement in performance on retesting that is due to previous exposure to the same or similar neuropsychological measures rather than to a true change

in the individual’s ability due to improved condition.” Docket No. 39 at p. 1. The court finds the concept sufficiently self-explanatory that it can be described to the factfinder without requiring the recording of the examinations.

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Related

Schlagenhauf v. Holder
379 U.S. 104 (Supreme Court, 1965)
Lorraine Sanden v. Mayo Clinic
495 F.2d 221 (Eighth Circuit, 1974)
Thompson v. Nix
897 F.2d 356 (Eighth Circuit, 1990)
Tomlin v. Holecek
150 F.R.D. 628 (D. Minnesota, 1993)
Holland v. United States
182 F.R.D. 493 (D. South Carolina, 1998)

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Durfee v. GPEX Transport, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/durfee-v-gpex-transport-inc-sdd-2024.