Keeton v. Moss Point School District

CourtDistrict Court, S.D. Mississippi
DecidedJanuary 10, 2024
Docket1:22-cv-00195
StatusUnknown

This text of Keeton v. Moss Point School District (Keeton v. Moss Point School District) is published on Counsel Stack Legal Research, covering District Court, S.D. Mississippi primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keeton v. Moss Point School District, (S.D. Miss. 2024).

Opinion

FORIN T THHEE S UONUITTHEEDR SNT ADTISETSR DICISTT ORFIC MTI CSSOIUSRSITP PI SOUTHERN DIVISION

COLLETTE LA TRESE KEETON § PLAINTIFF § § v. § Civil No. 1:22-cv-195-HSO-BWR § § MOSS POINT SCHOOL DISTRICT § DEFENDANT

ORDER GRANTING MOTION [27] TO DISMISS AND DISMISSING CASE WITHOUT PREJUDICE AS A DISCOVERY SANCTION AND FOR FAILURE TO PROSECUTE OR COMPLY WITH ORDER [26] COMPELLING PLAINTIFF TO SIT FOR A DEPOSITION

THIS MATTER is before the Court on Defendant Moss Point School District’s (“Defendant” or “Moss Point”) Motion [27] to Dismiss and for case management purposes upon Plaintiff Collette La Trese Keeton’s (“Plaintiff” or “Keeton”) failure to comply with the Court’s prior Order [26] Compelling Plaintiff to Sit for a Deposition on or Before November 22, 2023. For the reasons that follow, the Court will grant Defendant’s Motion [27] to Dismiss and dismiss this case without prejudice as a discovery sanction and for Plaintiff’s failure to sit for her deposition and for her failure to prosecute or obey the Court’s prior Order [26]. I. BACKGROUND Plaintiff Keeton filed this action pro se on July 28, 2022. Compl. [1]. She alleged various forms of employment discrimination, including age discrimination, disability discrimination, sex discrimination, and retaliation. Id. She attached two documents from the Equal Employment Opportunity Commission (“EEOC”): a letter dated March 30, 2022, stating that the EEOC had “issued [an] enclosed Dismissal and Notice of Rights” letter that she had not yet downloaded from the EEOC’s online portal, which triggered a 90-day period to file a lawsuit for employment

discrimination, Doc. [1-2]; and a subsequent “Determination and Notice of Rights” letter dated July 18, 2022, informing her that the EEOC would not proceed further with its investigation and that she had 90 days from the date of receipt of the letter to file a lawsuit, Doc. [1-3]. A settlement conference was held on September 29, 2023. Order [26] at 1. As the Court’s Order [26] explains, “Moss Point’s counsel discussed that taking Keeton’s deposition before the October 6, 2023 discovery deadline was necessary

because Keeton’s Amended Complaint [4] was difficult to interpret,” and “Keeton agreed to sit for a deposition on October 4, 2023, at 10:00 a.m. by Zoom videoconferencing.” Order [26] at 1. Defendant’s counsel then filed with the Court, and mailed to Keeton at her address of record, a Notice of Deposition [23]. Although “[a] court reporter was prepared to start at the designated time, [] less than an hour before the deposition, Keeton emailed Moss Point’s counsel and informed him that

she would be unavailable for the deposition and asked to reschedule.” Order [26] at 2. The email reads, “May I please reschedule for later today or for tomorrow? I am en route to several appointments.” Doc. [27-7] at 1. Plaintiff did not move for a protective order. See Fed. R. Civ. P. 37(d)(2) (providing that “[a] failure described in Rule 37(d)(1)(A),” which includes a party’s failure to appear for a deposition, “is not excused on the ground that the discovery sought was objectionable, unless the party failing to act has a pending motion for a protective order under Rule 26(c)”). On October 20, 2023, Moss Point moved to dismiss the case as a discovery sanction under Federal Rule of Civil Procedure 37, or alternatively to compel

Plaintiff to sit for a deposition. Mot. [24]. The Court entered an Order [26] Compelling Plaintiff to Sit for a Deposition on or Before November 22, 2023, warning Plaintiff that if she did not do so, “this case may be dismissed as a discovery sanction under Federal Rule of Civil Procedure 37(d) and for failure to prosecute and obey a Court Order under Federal Rule of Civil Procedure 41(b).” Order [26] at 1. The docket indicates that the Order [26] was mailed to Plaintiff’s address of record, and it was not returned as undeliverable.

On November 8, 2023, Defendant’s counsel sent Plaintiff an email and mailed her a letter in which he provided his availability to take her deposition before the November 22, 2023 deadline. Doc. [27-9], [27-10]. Counsel mailed the letter to Plaintiff’s address of record, though the envelope indicates it was evidently returned; it is marked “Return to Sender”; “Attempted - Not Known”; “Unable to Forward.” Doc. [27-10] at 1.1 Counsel also sent an email with the letter attached to

Plaintiff’s email address that she had used to inform Defendant’s counsel that she was cancelling the October 4, 2023 deposition. Doc. [27-9] at 1–2, see Doc. [27-7] at 1. On November 27, 2023, Defendant moved to dismiss this case, stating, “November 22, 2023 has elapsed and Plaintiff has not sat for her deposition nor has

1 Plaintiff has not filed a new address with the Court. she engaged with Movant in seeking to accomplish the same.” Mot. [27] at 2. Plaintiff has not filed a response to Defendant’s Motion [27] to Dismiss and the record lacks any indication that she has attempted to sit for a deposition or

otherwise prosecute her case. The discovery deadline in this case passed on December 6, 2023. II. DISCUSSION Federal Rule of Civil Procedure 37(d) provides that the Court may order sanctions where a party “fails, after being served with proper notice, to appear for that person’s deposition.” Fed. R. Civ. P. 37(d)(1)(A)(i). Sanctions may include dismissing the action. Fed. R. Civ. P. 37(b)(2)(A)(v); see Roy v. ADM Grow Mark,

211 F.3d 593, 2000 WL 329273, at *3 (5th Cir. 2000) (unpublished table decision) (“Under Rule 37(d), a party refusing to attend his own deposition can be sanctioned under Rule 37(b). Among the sanctions available to a district court under Rule 37(b) is dismissal of the action with prejudice.”). “Deliberate, repeated refusals to comply with discovery orders have been held to justify the use of this ultimate sanction.” Bonaventure v. Butler, 593 F.2d 625, 626 (5th Cir.1979) (affirming

dismissal when the plaintiff refused to appear for a deposition three times). The Fifth Circuit has also explained that “[a] district court may dismiss an action for failure of a plaintiff to prosecute or to comply with any order of court,” and “possesses the inherent authority to dismiss the action sua sponte, without motion by a defendant.” McCullough v. Lynaugh, 835 F.2d 1126, 1127 (5th Cir. 1988) (first citing Fed. R. Civ. P. 41(b); then Link v. Wabash R.R. Co., 370 U.S. 626, 630–31 (1962)). The Court has reviewed the record and it reveals that Plaintiff has twice failed to sit for a deposition. She first agreed to schedule one for October 4, 2023,

but she canceled without a legitimate explanation about an hour before the deposition.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Keeton v. Moss Point School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keeton-v-moss-point-school-district-mssd-2024.