Hoy v. Holmes

28 Pa. D. & C.5th 9
CourtPennsylvania Court of Common Pleas, Schuylkill County
DecidedJanuary 31, 2013
DocketNo. S-57-12
StatusPublished

This text of 28 Pa. D. & C.5th 9 (Hoy v. Holmes) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Schuylkill County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoy v. Holmes, 28 Pa. D. & C.5th 9 (Pa. Super. Ct. 2013).

Opinion

DOMALKES, J.,

The matter before the court is a motion to compel discovery responses filed by the defendant, Stephen Holmes (hereinafter ‘Holmes’). The plaintiffs, Sonya Hoy and Brock Herb, her son (hereinafter ‘Hoy’ and ‘Herb’), have filed an answer to the motion. The parties have presented written arguments to the court concerning their positions. The court has reviewed the foregoing and the relevant record.

The underlying lawsuit involves an automobile accident. Hoy and Herb filed suit against Holmes claiming damages from the accident, she for present and future mental suffering, present and future pain and suffering, medical expenses, lost earning capacity, and uncompensated work loss, and he for present and future mental suffering, present and future pain and suffering, medical expenses, lost earning capacity, and uncompensated work loss. Holmes has sought discovery from Hoy and Herb in three particular areas, those being: social media, prior or subsequent accidents, and income tax records. The court will discuss the discovery requests seriatim as hereinafter set forth.

Social Media

Holmes wants access to information of any social [12]*12media internet accounts of Hoy, for example Facebook. He argues that, by filing a lawsuit and claiming certain injuries, both physical and mental, he is entitled to view the social media accounts of Hoy for information that may help his defense or which concerns her damage claims, or he may find information that might lead to discoverable material. He argues that such discovery is authorized by certain federal lower court decisions from other states but has not cited any Pennsylvania appellate court or Pennsylvania federal court decisions.

Hoy argues, in opposition to this request, that it is overly broad and does not seek relevant and discoverable information. There has been no showing that any of the information requested is relevant or will lead to relevant or discoverable information. Plaintiff argues that the majority of cases of Pennsylvania Common Pleas Courts on this issue hold that discovery of social media is only permitted after a showing that the public portion of a person’s internet profile supports an argument that relevant information may be available on the private portion. Holmes cites Trail v. Lesko, 2012 Pa. Dist. & Cnty. Dec. LEXIS 194 (C.P. Allegheny 2012). That case held that a threshold showing of relevance is necessary prior to permitting discoveiy of the non-public portions of the social media. Plaintiffs argue that Holmes is simply on a fishing expedition, has not articulated a factual basis for his social media requests and only intends to harass, embarrass, and unduly burden Hoy.

In Trail, supra, the Allegheny County court explained [13]*13that social media, such as Facebook, contains a public profile open and available to anyone and a non-public profile which is considered to be private. The court reviewed a number of trial court Pennsylvania cases and reached a conclusion on the very issue presently before this court. Its conclusion was in accord with Hoy’s argument as to the correct discovery standard to be applied. The court wrote: “The courts recognize the need for a threshold showing of relevance prior to discovery of any kind, and have nearly all required a party seeking discoveiy in these cases to articulate some facts (emphasis added) that suggest relevant information may be contained within the non-public portions of the profile. To this end, the courts have relied on information contained in the publicly available portions of a user’s profile to form a basis for further discovery.” In McMillen v. Hummingbird Speedway Inc., 2010 WL 4403285, No. 113-CD (Jefferson CP. Sep. 9, 2010), the Jefferson County trial court held that, because the public profile showed that relevant information might have been contained in the private profile demonstrating that the plaintiff’s injuries were exaggerated and because there exists no privilege between friends on the social media account, and even if such a privilege did exist, it was waived by posting on that account, it was proper for the court to order the requested discovery. In Zimmerman v. Weis Markets, Inc., 2011 WL 2065410, No. CV-09-1535 (Northumberland CP. May 19, 2011), the Northumberland County court decided that, on the basis of publicly-available information, it was reasonable to infer the existence of added relevant [14]*14content within the private profile of the plaintiff’s profile. The court noted that, although the plaintiff had argued that he had a reasonable expectation of privacy on this matter, the plaintiff consented to share the information when he created the account and voluntarily posted the information. It thus ordered that plaintiff comply with the discovery request. Here, too, in accordance with McMillen, supra, the court limited its holding to requests founded on “some factual predicate gleaned from the publicly available pages (emphasis added),” requiring some threshold that the public portions of an internet profile contained information that points to additional relevant information in the nonpublic portions of the profile. In Largent v. Reed, 2011 WL 5632688, No. 2009-1823 (Franklin CP. Nov. 8, 2001), the Franklin County court held that, because non-public information on a Facebook account is shared with others, there exists no reasonable privacy expectation. The very purpose for a Facebook account is to share information with others, which purpose nullifies any claim of privilege. As in the two prior cases, the Largent court confined its holding to those cases whereby the party seeking discovery can articulate in good faith that further discovery will lead to relevant information. In Arcq v. Fields, No. 2008-2430 (Franklin CP. Dec. 2011), the Franklin County court held that this type of request was predicated on a showing that the public portions of the subject profile contained relevant information establishing a gateway to the nonpublic portion and that there had to be articulated some reasonable, good-faith basis for thinking that the private profile contained relevant information for the discovery [15]*15request for the non-public information to be granted.

This court has also reviewed the article on local court cases pertaining to this issue published in Pennsylvania Law Weekly, December 11, 2012, Vol. XXXV No. 50, entitled Trial Courts Yet to Find Consistency in Facebook Race In this article, it is noted that there is presently no Pennsylvania appellate court decisions on this question, and the trial court decisions dealing with it are divided, some allowing, some denying the discovery. However, it is noted in the article that there is a common ground among the decisions. The article contains the following observation: “If there’s been a common thread among courts landing on both sides of the issue - though not universal - it’s the public-to-private rationale. Judges have, in most cases, granted access to a party’s private account when something available on their “public page” indicates that more discovery is warranted, or denied for the same reason.” The article goes on to explain that the trial court opinions continue to be both pro and con the factual predicate standard. A recent case out of the Indiana County Court of Common Pleas, Simms v. Lewis was cited as being in favor of the standard.

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28 Pa. D. & C.5th 9, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoy-v-holmes-pactcomplschuyl-2013.