Jacoby v. Board of Supervisors of the University of Louisiana System

District Court, E.D. California·Decided February 1, 2024·No. 2:23-cv-02848·Unknown

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 KENNETH JACOBY, No. 2:23-cv-02848 KJM AC 11 Moving Party, 12 v. ORDER 13 BOARD OF SUPERVISORS OF THE UNIVERSITY OF LOUISIANA 14 SYSTEM, 15 Responding Party. 16 17 This case was opened on December 6, 2023, with the filing of a motion for protective 18 order regarding a deposition subpoena directed to journalist Kenneth Jacoby. ECF No. 1. That 19 motion is now before the court. This matter is related to a miscellaneous case that was previously 20 opened in order for the court to hear Jacoby’s November 13, 2023 Motion to Quash a documents 21 subpoena that had been served upon him on October 31, 2023 by the Board of Supervisors of the 22 University of Louisiana System (“ULS”), which is a defendant in the underlying case Jane Doe v. 23 Board of Supervisors of the University of Louisiana System, et al., No. 22-cv-00338-BAJ-SDJ, 24 pending in the U.S. District Court for the Middle District of Louisiana. Jacoby v. Board of 25 Supervisors of the University of Louisiana System, 2:23-mc-00403-KJM-AC (“Jacoby I”). 26 Jacoby is not a party to the underlying case. A joint statement regarding the instant motion was 27 filed on January 18, 2024 (ECF No. 9) and the matter was heard via Zoom court on January 31, 28 2024. For the reasons set forth below, the motion for a protective order is GRANTED. 1 I. Relevant Background 2 The moving party, Kenneth Jacoby, is a journalist who wrote an article published in USA 3 Today on May 26, 2021 entitled “Six women reported a Louisiana college student for sexual 4 misconduct. No one connected the dots.” (“the Article”). ECF No. 9 at 7-8. A year after the 5 Article’s publication, Jane Doe, one of the women who reported Victor Daniel Silva to ULS for 6 assault, filed her lawsuit in the United States District Court for the Middle District of Louisiana 7 against The Board of Supervisors of the University of Louisiana System (“ULS”) and others, 8 asserting claims for Title IX and negligence under Louisiana state law. One of USL’s defenses in 9 the underlying action is that the claim is time-barred, raising the issue of when Doe learned about 10 the facts giving rise to her claims. Id. 11 Doe claims she learned about the material facts that form the basis of her lawsuit, for the 12 first time, when she read Jacoby’s article on May 26, 2021. Jacoby I at ECF No. 11 at 29. 13 However, at her deposition, Doe testified that she spoke with Jacoby about the article and 14 exchanged written communication with him before the article was published. Id. at 30. At issue 15 in Jacoby I was a documents subpoena issued by ULS to Jacoby to obtain information regarding 16 what Doe discussed with Jacoby prior to the article’s publication. ULS sought the documents in 17 order to analyze the overlap between the information published in Jacoby’s article and the 18 information discussed in Doe’s communications with Jacoby before the article was published. 19 With respect to Jacoby I, following meet and confer efforts, “ULS agreed to narrow the 20 scope of the subpoena, which contains 28 document requests to non-party Jacoby, to include only 21 the following (1) notes from conversations between Jacoby and Jane Doe from December 2018 to 22 May 26, 2021; (2) text messages between Jacoby and Jane Doe from December 2018 to May 26, 23 2021; and (3) an affidavit from Jacoby authenticating copies of the production and providing a 24 context for the production.” ECF No. 11 at 6. Jacoby prepared a declaration (Jacoby I at ECF 25 No. 11-1) and proposed it to ULS on November 28, 2023, but ULS found the declaration 26 insufficient and maintained its request for the three items noted above. The resulting impasses 27 necessitated a motion to quash that subpoena. 28 //// 1 Jacoby moved to quash the documents subpoena on the grounds that it directly 2 contravened his rights as a journalist under the robust protections of the U.S. Constitution, 3 California Constitution, California state law, and the common law. Jacoby I at ECF No. 11 at 8. 4 In evaluating the motion, the court relied on the Ninth Circuit’s interpretation the Supreme Court 5 case Branzburg v. Hayes, 408 U.S. 665 (1972) as establishing a qualified privilege for journalists 6 against compelled disclosure of information gathered in the course of their work. Shoen v. 7 Shoen, 5 F.3d 1289, 1292 (9th Cir. 1993). “Rooted in the First Amendment, the privilege is a 8 recognition that society’s interest in protecting the integrity of the newsgathering process, and in 9 ensuring the free flow of information to the public, is an interest ‘of sufficient social importance 10 to justify some incidental sacrifice of sources of facts needed in the administration of justice.’” 11 Id. at 1292 (quoting Herbert v. Lando, 441 U.S. 153, 183 (1979) (Brennan, J., dissenting) 12 (internal quotation omitted)). The court noted that the Ninth Circuit went on to hold that 13 compelled disclosure of unpublished newsgathering material is only permissible “upon a showing 14 that the requested material is: (1) unavailable despite exhaustion of all reasonable alternative 15 sources; (2) non-cumulative; and (3) clearly relevant to an important issue in the case.” Shoen v. 16 Shoen (“Shoen II”), 48 F.3d 412, 416 (9th Cir. 1995). 17 In Jacoby I, the undersigned found the subpoena did not meet the standard necessary to 18 invade Jacoby’s journalistic protections under the First Amendment. First, the court concluded 19 ULS had not made a sufficient showing that the sought-after discovery was non-cumulative. Jane 20 Doe had already produced text messages between herself and Jacoby, which date no earlier than 21 December 10, 2020. Jacoby I at Jassy Decl. ¶ 9(e). Further, the court concluded Jacoby’s 22 declaration resolved any uncertainty regarding the first dates and means of contact; Jacoby 23 confirmed in a sworn declaration that his December 9, 2020 email, December 10, 2020 phone 24 call, and December 10, 2020 text messages were his first communications with Jane Doe. Jacoby 25 I at Jacoby Decl. ¶ 3. 26 The undersigned also concluded that the rationale presented by ULS that Jacoby’s 27 declaration was insufficient was speculative. ULS contended that it recently deposed another 28 woman identified in the article, Andie Richard, who confirmed that she communicated with 1 Jacoby approximately three months before the article was published, and while “ULS recognizes 2 that Doe and Richard are different witnesses . . . because Doe and Richard were both sources for 3 the article, Defendant anticipates that Jacoby provided both sources with similar information 4 about the contents of his article.” Jacoby I at ECF No. 11 at 24-25. The undersigned found this 5 speculative argument was no reason to discount Jacoby’s sworn statement regarding the earliest 6 date of his communication with Doe, nor did it cast legitimate doubt on the truth of Doe’s 7 deposition. The court noted that Doe had already testified extensively about the substance of her 8 communications with Jacoby and had already confirmed that she did not see the article before it 9 was published. Jacoby I at Jassy Decl. ¶ 13, Ex. 6, Tr. 321:2–329:3, 308:24–309:19. Further, the 10 court noted that ULS already had all the relevant text messages between Jacoby and Doe, as 11 produced by Jane Doe. Jacoby I at Jassy Decl. ¶ 9(e). Based on this analysis, the undersigned 12 concluded the third-party document subpoena to Jacoby was unnecessary and cumulative.

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