Hill 282429 v. Maricopa County Sheriff's Office

District Court, D. Arizona·Decided May 22, 2020·No. 2:18-cv-02613·Unknown

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA 8 9 Justin Dwayne Hill, No. CV 18-02613-PHX-GMS (MTM) 10 Plaintiff, 11 v. ORDER 12 Maricopa County Sheriff’s Office, et al., 13 Defendants.

14 15 Pending before the Court are five Appeals of Magistrate Judge Decision to District 16 Court by Plaintiff Justin Dwayne Hill. (Doc. 220, 259, 260, 261, and 262.) 17 Pursuant to Federal Rule of Civil Procedure 72(a), parties may file objections to a 18 magistrate judge order within fourteen days after being served with a copy of the order. 19 The Court must then consider these objections and “modify or set aside any part of the 20 order that is clearly erroneous or is contrary to law.” Fed. R. Civ. P. 72(a). As all of 21 Plaintiff’s objections were timely, the Court considers each. 22 I. Doc. 220 23 Plaintiff first objects to an order, Doc. 211, denying his request for the appointment 24 of an investigator, Doc 202, and his various attempts to oblige Defendants to make video 25 and audio recordings relevant to his case accessible for his review, Docs. 203, 204, and 26 205. In three separate requests, Plaintiff attempted to compel access to various audio and 27 video footage that he is otherwise unable to view. In Doc. 203, Plaintiff requested that the 28 Court order a hearing at which such recordings could be played for him. In Doc. 204, he 1 requested that the Court order that Defendants’ Attorney personally be ordered to set up a 2 call with him to play the audio recorded interviews of Defendants Martin and Yu over the 3 telephone. In Doc. 205, Plaintiff requested that the Court order Defendants to “provide the 4 means for me to view and listen to audio/video evidence concerning this matter.” 5 As an initial matter, this Court upholds the denial of the appointment of an 6 investigator. Plaintiff has not come close to meeting the standard required for such an 7 appointment. As it pertains to the recordings, in their terse Response, Defendants noted 8 that Plaintiff was being denied direct access to the evidence because he is incarcerated and 9 providing the recordings would breach safety protocol and could endanger other inmates 10 or detention officers. Defendants further noted that the recordings were available and 11 would be produced to Plaintiff’s designee rather than to Plaintiff. Defendants did not set 12 forth any particular safety protocol that would be violated by providing the Plaintiff access 13 to the recordings, nor did they explain how giving direct access to the Defendant to the 14 recordings “could endanger other inmates or detention officers.” 15 “[U]pon request, an inmate is entitled to access prison video surveillance evidence 16 pertaining to his or her disciplinary proceeding unless the government establishes that 17 disclosure of such evidence would be, under the particular circumstances of the case, 18 ‘unduly hazardous to institutional safety or correction goals.’” Lennear v. Wilson, 937 F.3d 19 257, 271-72 (4th Cir. 2019) (quoting Wolff v. McDonnell, 418 U.S. 539, 566 (1974)). 20 Prison officials bear the burden of providing evidence justifying their denial of a prisoner’s 21 request for access to documentary evidence, including video surveillance footage. Id. at 22 270. “[I]f prison officials fail to identify a specific safety or correctional concern, courts 23 may not ‘speculate’ as to the officials’ potential reasons for denying an inmate access to 24 evidence. . . .” Id. 25 Defendants suggest in their motion papers that Plaintiff will not be able to view the 26 video evidence or hear the audio except through a summary prepared by a designee. But 27 Defendants offer no explanation as to why it would breach policy or be unadvisable to 28 allow Plaintiff to create conditions in which it would be possible for him to view and hear 1 the recordings he seeks without endangering other inmates or detention officers. Without 2 more specifics, Defendants have not provided a sufficient justification on which to deny 3 Plaintiff access to the recordings. 4 Certainly, the Magistrate Judge was correct in noting that Defendants’ attorney need 5 not play the recordings for the Plaintiff; nor does the Court have to schedule a hearing to 6 accomplish such a result. But the generic reasons offered by Defendants for refusing to 7 provide Plaintiff with access to the recordings are insufficient. To accomplish such a denial 8 of access to Plaintiff would hamper Plaintiff’s ability to prepare for his case by effectively 9 limiting his right to discovery. Although “[p]rison security” is, “in appropriate 10 circumstances, a factor which justifies a limitation on otherwise appropriate discovery as 11 unduly burdensome,” it is not “a magic incantation that allows prison officials to refuse to 12 participate in the litigation process.” Pettit v. Ryan, No. CV112139PHXDGCJFM, 2012 13 WL 13167975, at *2 (D. Ariz. Dec. 20, 2012). While reasonable security steps can be taken 14 in allowing Plaintiff to view the requested video and audio tapes, the Magistrate Judge’s 15 order is set aside and Plaintiff’s request for Defendants to make video and audio recordings 16 accessible for his review is granted, absent further justification why they should be 17 withheld. 18 II. Doc. 259 19 Plaintiff objects to Doc. 248 denying his motion for in camera review and to compel 20 Defendants to produce withheld documents, Doc. 213. On August 16, 2019, Plaintiff 21 served Defendants “with a request for production 1-9,” number two of the request being 22 “the prosecution file pertaining to the charges against [Plaintiff] retained by the MCAO.” 23 (Doc. 259 at 1.) On January 5, 2020, Plaintiff received the requested file and learned that 24 Defendants had withheld several documents. Plaintiff accordingly filed Doc. 213 the 25 following day, describing not only the withheld documents but also Defendants’ response 26 during a video conference on December 27, 2019 that some of Plaintiff’s requested 27 materials were privileged. On February 21, 2020, the Magistrate Judge denied Plaintiff’s 28 motion as untimely because, pursuant to the Court’s scheduling order (Doc. 39), all 1 Motions pertaining to discovery were required to be filed by October 31, 2019, and 2 “Plaintiff state[d] that on August 16, 2019 – two months ahead of the discovery deadline – 3 he received ‘about 35 pages’ from Defendants in response to his request.” (Doc. 248 at 4.) 4 However, Plaintiff did not state that he received documents on August 16, 2019, but rather 5 than he requested documents on that date. He stated that he received the documents on 6 January 4, 2020. Given that the Magistrate Judge apparently misread this fact and that 7 Defendants failed to produce the requested file until January 2020 (for which they have 8 provided no explanation, in response to either Doc. 211 or Doc. 259, despite the Court’s 9 request that they respond to Doc. 259), this first basis for denying Plaintiff’s motion is 10 clearly erroneous. 11 The Magistrate Judge also denied the motion on the basis that it failed to comply 12 with LRCiv 37.1 because the Magistrate could not determine “based on Plaintiff’s 13 conclusory statements that Defendants’ statements concerning the content of the 14 documents and the applicability of any privileges [we]re deficient.” (Doc.

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Hill 282429 v. Maricopa County Sheriff's Office, (D. Ariz. 2020).

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