Lamaute v. Steele

CourtDistrict Court, District of Columbia
DecidedMay 18, 2021
DocketCivil Action No. 2019-3702
StatusPublished

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Bluebook
Lamaute v. Steele, (D.D.C. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

DENISE LAMAUTE,

Plaint{[!,.

v. Case No. 1:19-cv-3702-RCL

SAMANTHA POWER, Administrator, U.S. Agency.for International Development, 1

Defendant.

MEMORANDUM OP.I ION

Before the Court is plaintiff Denise Lamaute's motion to compel defendant United States

Agency for International Development to produce documents responsive to her First Set of

Requests for Production of Documents. ECF No. 19. For the reasons stated below, Lamaute's

motion to compel will be granted in part and denied in part.

I. BACKGROUND

Lamaute is a sixty-seven year-old, Black woman who has worked at the Agency for almost

two decades. Comp!. ir 7. She claims that the Agency discriminated against her on the basis of race, sex, and age, in violation of Title VII of the Civil Rights Act of 1964, 42 lJ .S.C. § 2000e et

seq., and the Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq., when it selected

Mark Pickett, a white man, over her for a senior level position she applied for in 2017. Lamaute

alkges that · she was objectively more qualified for the GS-15 supervisory business specialist

position she applied for in the Agency's Bureau for Europe and Eurasia. Mainly, she alleges that

her years of experience and expertise in the economic growth sector makes her the objectively

1 On May 3, 2021, Samantha Power was sworn in as the Administrator of the U.S. Agency for International Development and was automatically substituted as the named defendant. .'-:i'ee Fed. R. Civ. P. 25(d). better candidate compared to Pickett, who had fewer years of experience related to economic

growth. Id. at ~~ 62-145. Lamaute further alleges that the Agency deviated from standard hiring

practices and procedures during the hiring process. For instance, she alleges that the Agency failed

to ensure a diversity-conscious hiring process, because the three-person hiring committee that

interviewed her and Pickett for the position was comprised entirely of white men, and because the

Agency did not provide diversity information for the hiring committee to review during the hiring

process. Id. at ~~ 41-44. She also alleges that the hiring committee asked Lamaute and Pickett

different questions during their respective interviews. Id. at iii! 46-54. Last May, Lamaute served her first set of interrogatories and requests for production of

documents on the Agency. Mot., Ex. A. Defendants responded to some requests and objected to

other requests. Mot., Ex. B. Lainaute asserted that several of the responses were inadequate. Mot.,

Ex. C. Between October 2020 and December 2020, the parties met and conferred twice and

exchanged emails, and they resolved some of the discovery disputes. Mot. at 5. Yet, Lamaute

argues that the Agency "has failed to produce complete responses to the majority of [her] requests."

Id. She filed her motion to compel the Agency to produce documents to the full extent requested.

Specifically, she seeks complete responses to her Requests for Production of Documents Nos. 3,

4, 5, 6, 7, 8, and 11. Lamaute contends that the requested discovery is relevant and proportional to

her Title VII and ADEA discrimination claim. See id The Agency opposed the motion, asserting

that her requests seek non-relevant information or are not proportional to the needs of the case.

Def.'s Opp'n. (ECF No. 26). Lamaute replied, reasserting the relevance and proportionality of her

requests. Reply (ECF No. 27).

After briefing was complete, the Agency supplemented its discovery responses. Notice,

ECF No. 29. It provided five additional documents in response to Request for Production No. 8.

2 II. LEGAL STANDARD

A party may submit to another party a request for production of documents "within the

scope of Rule 26(b)." Fed. R. Civ. P. 34(a). Under Rule 26(b)(l) of Federal Rule,s of Civil

Procedure, "[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to

any party's claim or defense and proportional to the needs of the case, considering [ 1:J the

importance of the issues at stake in the action, [2] the amount in controversy, [3] the parties'

relative access to relevant information, [4] the parties' resources, [5] the importance of the

discovery in resolving the issues, and [6] whether the burden or expense of the proposed discovery

outweighs its likely benefit." In short, considerations of both relevance and proportionality govern

the scope of discovery. See Fed. R. Civ. P. 26(b)(l ); Fed . R. Civ. P. 26 advisory committee's notes

to 2015 amendment. If the court determines that the proposed discovery is outside the scope

permitted by Rule 26(6)(1), then it must limit the extent of discovery accordingly. See Fed. R. Civ.

P. 26(6)(2)(C).

Relevance, for discovery purposes, has been "'construed broadly to encompass any matter

that bears on, or that reasonably could lead to other matter that could bear on' any party's claim or

defense." United States ex rel. Shamesh v. CA, Inc., 314 F.R.D. 1, 8 (D.D.C. 2016) (quoting

Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340,351 (1978)). While plaintiffs in discrimination

cases have been permitted a broad scope of discovery, "the relevance standard of Rule 26 is not

without bite." Food Lion, Inc. v. United Food & Com. Workers Inr 'l Union, AFL-CIO-CLC, 103

F.3d 1007, 1012 (D.C. Cir. 1997) (citation omitted). In discrimination cases, "courts remain

concerned about 'fishing expeditions, discovery abuse, and inordinate expenses involved in

overbroad and far-ranging discovery requests' and have therefore limited discovery to the issues

involved in the particular case." Pleasants v. Al!baugh, 208 F.R.D. 7, 9 (D.D.C. 2002) (quoting

Hardrick, 96 F.R.D. 617, 618 (D.D.C. 1983)). Courts may exercise discretion in discrimination

3 cases by placing reasonable limits in discovery in order to balance the needs and rights of both

plaintiff and defendant. See Glenn v. Williams, 209 F.R.D. 279, 282 (D.D.C. 2002) (citation

omitted). The consideration of proportionality involves balancing the six factors identified in Rule

26(b )(1 ), where "[ nJo single :factor is designed to outweigh the other factors in determining

whether the discovery sought is proportional." Oxbow Carbon & Mins. LLC v. Union Pac. R.R.

Co., 322 F.R.D. 1, 6 (D.D.C. 2017) (internal quotation mark and citation omitted).

When a party objects to a discovery request, the requesting party may-after first

attempting to resolve the issue by conferring with the refusing party-file a motion to compel. Fed.

R. Civ. P. 3 7(a)(l ). The party that brings the motion to compel bears the initial burden of

"explaining how the requested information is relevant." Oxbow Carbon, 322 F.R.D. at 5-6; see

also Fed. R. Civ. P. 26

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