Hiatt v. Sun City Festival Community Association Incorporated

CourtDistrict Court, D. Arizona
DecidedJuly 1, 2024
Docket2:23-cv-00552
StatusUnknown

This text of Hiatt v. Sun City Festival Community Association Incorporated (Hiatt v. Sun City Festival Community Association Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hiatt v. Sun City Festival Community Association Incorporated, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8

Wayne Hiatt, ) No. CV-23-00552-PHX-SPL ) 9 ) 10 Plaintiff, ) ORDER vs. ) ) 11 ) Sun City Festival Community ) 12 Association Incorporated, ) 13 ) ) 14 Defendant. )

15 Several motions are pending before the Court: (1) Plaintiff Wayne Hiatt’s Motion 16 for Hearing or Conference re: Rule 16 Status Conference (Doc. 37); (2) the parties’ Joint 17 Motion for Discovery Dispute Resolution (Doc. 39); (3) Defendant Sun City Festival 18 Community Association Incorporated’s Ex Parte Motion to Disqualify Counsel Dessaules 19 Law Group (Doc. 42); (4) Defendant’s Ex Parte Motion to Stay Remaining Case Deadlines 20 (Doc. 43); (5) Defendant’s Motion to Seal Document Exhibits 4 and 5 (Doc. 44); (6) 21 Plaintiff’s Motion for Sanctions under Fed. R. Civ. P. 37(c) and (d) (Doc. 47); and (7) 22 Defendant’s Ex Parte Second Motion to Seal Document (Doc. 58). The motions are 23 addressed below. 24 I. BACKGROUND 25 On March 31, 2023, Plaintiff filed a two-count Complaint against Defendant Sun 26 City Festival Community Association (the “Association” or “Defendant”) alleging 27 discrimination under the Fair Housing Act (“FHA”), 42 U.S.C. §§ 3601, et seq., and the 28 Arizona Fair Housing Act (“Arizona FHA”), A.R.S. § 41-1491.19(B). (Doc. 1). Plaintiff 1 alleges that he is a disabled veteran who suffers from a disability. (Doc. 1 at ¶ 8). Plaintiff 2 engages in therapy in the form of woodwork to help reduce the symptoms associated with 3 his disability. (Id. at ¶ 10). Plaintiff alleges that his garage is the only place where he can 4 engage in woodwork. (Id.). The Association’s Declaration prohibits open garage doors and 5 further provides that garage doors “shall remain closed at all times except when entering 6 or exiting the garage.” (Doc. 1 at ¶ 6; Doc. 7 at ¶ 6). Because leaving the garage door closed 7 often triggers his disability, however, Plaintiff claims that he needs to keep his garage door 8 open while he is woodworking inside of his garage. (Doc. 1 at ¶ 10). 9 In November 2022, Plaintiff sent the Association a request for accommodation 10 under the FHA to keep his garage door open while he is woodworking. (Id. at ¶ 11). In 11 January 2023, the Association’s counsel at the time, Sarah McCue, sent Plaintiff a letter 12 denying his accommodation request. (Id. at ¶ 17). Plaintiff filed this lawsuit shortly after 13 receiving Ms. McCue’s denial letter. (Id.). 14 II. DISCUSSION 15 a. Motions for Sanctions and Rule 16 Status Conference 16 Federal Rule of Civil Procedure (“Rule”) 37(c)(1) provides the following: 17 If a party fails to provide information or identify a witness as 18 required by Rule 26(a) or (e), the party is not allowed to use that information or witness to supply evidence on a motion, at 19 a hearing, or at a trial, unless the failure was substantially justified or is harmless. 20 21 The burden to show that the violation of Rule 26(a) is substantially justified or harmless is 22 on the party facing sanctions. Yeti by Molly, Ltd. v. Deckers Outdoor Corp., 259 F.3d 1101, 23 1107 (9th Cir. 2001); see also R & R Sails, Inc. v. Ins. Co. of Pa., 673 F.3d 1240, 1246 (9th 24 Cir. 2012). When evaluating substantial justification and harmlessness, courts often 25 consider (1) prejudice or surprise to the other party, (2) the ability of that party to cure the 26 prejudice, (3) the likelihood of disruption of trial, and (4) willfulness or bad faith. Lanard 27 Toys Ltd. v. Novelty, Inc., 375 F. App’x 705, 713 (9th Cir. 2010). 28 1 This provision is a “self-executing sanction.” Fed. R. Civ. P. 37 advisory 2 committee’s note (1993); see also Merchant v. Corizon Health, Inc., 993 F.3d 733, 740 3 (9th Cir. 2021) (“Rule 37(c)(1) is an ‘automatic’ sanction that prohibits the use of 4 improperly disclosed evidence.”). Still, exclusion of evidence is not a necessary sanction, 5 as Rule 37(c)(1) authorizes other sanctions “in addition to or instead of” exclusion. See 6 Merchant, 993 F.3d at 740. “A party facing sanctions . . . bears the burden of showing that 7 a sanction other than exclusion is better suited to the circumstances,” and the Court need 8 not consider a lesser sanction than exclusion if the party facing sanctions does not move 9 for one. Id. at 741–42. 10 Rule 30 requires a corporation to designate a deponent sufficiently knowledgeable 11 to testify on the corporation’s behalf “about information known or reasonably available to 12 the corporation.” Fed. R. Civ. P. 30(b)(6). When a party notices topics for deposition, the 13 corporation must “not only produce such number of persons as will satisfy the request, but 14 more importantly, prepare them so that they may give complete, knowledge, and binding 15 answers on behalf of the corporation.” Guifu Li v. A Perfect Day Franchise, Inc., No. 10– 16 CV–01189–LHK, 2011 WL 3895118, at *2 (N.D. Cal. Aug. 29, 2011) (citation omitted). 17 Sanctions are available under Rule 37(d)(1)(A)(i) when “the failure to produce an 18 adequately prepared witness pursuant to Rule 30(b)(6) is tantamount to a failure to appear.” 19 JSR Micro, Inc. v. QBE Ins. Corp., No. C–09–03044 PJH (EDL), 2010 WL 1957465, at *2 20 (N.D. Cal. May 14, 2010) (citation omitted). 21 In the instant case, Plaintiff moves for sanctions against Defendant for failing to 22 timely disclose relevant emails and producing unprepared Rule 30(b)(6) designees. (Doc. 23 47 at 1). There is no dispute that Defendant disclosed email communications after the 24 discovery deadline. (Doc. 57 at 10). Defendant, however, argues that the untimely 25 disclosure was substantially justified and harmless. (Id. at 10). The email communications 26 revealed discussions between the Association’s board members regarding Plaintiff’s 27 request for accommodation. One email, from the Association’s board president, Bruce 28 Friedman, described the Association’s garage door rule as “stupid.” (Doc. 64 at 3–4; Doc. 1 57 at 11). In the same email, Mr. Friedman also stated that he did not need a lawyer “to 2 help [him] grant a reasonable accommodation in this case – as long as [Plaintiff] keeps [the 3 garage door] closed when he’s not in the garage.” (Doc. 47-1 at 2). 4 The Court finds that any prejudice from the late disclosure of the email 5 communications is harmless under the Lanard Toys factors. First, Defendant argues that 6 Plaintiff is unable to establish prejudice because the disclosure would not have 7 fundamentally altered the prosecution of his case. (Doc. 57 at 12). Defendant also argues 8 that Plaintiff misunderstood Mr. Friedman’s email as referring to Plaintiff’s request for 9 accommodations as “stupid.” (Doc. 57 at 10). This is not accurate. Plaintiff’s understanding 10 is that Mr. Friedman considers the garage door rule “stupid,” not Plaintiff’s request for 11 accommodation. (Doc. 47 at 14; Doc. 64 at 4). Plaintiff argues that Mr. Friedman’s opinion 12 that the garage door rule is “stupid” supports whether Plaintiff’s request for an 13 accommodation was reasonable. (Doc. 64 at 4).

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Hiatt v. Sun City Festival Community Association Incorporated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hiatt-v-sun-city-festival-community-association-incorporated-azd-2024.