Mello v. Arruda

CourtDistrict Court, D. Rhode Island
DecidedApril 28, 2025
Docket1:23-cv-00479
StatusUnknown

This text of Mello v. Arruda (Mello v. Arruda) is published on Counsel Stack Legal Research, covering District Court, D. Rhode Island primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Mello v. Arruda, (D.R.I. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF RHODE ISLAND

JOSHUA MELLO, : Plaintiff, : : v. : C.A. No. 23-479JJM : EDWARD ARRUDA, et al., : Defendants. : ____________________________________:

JOSHUA MELLO and RACHEL WARE, : Plaintiffs, : : v. : C.A. No. 23-480JJM : JOHN ROCCHIO, et al., : Defendants. : ____________________________________:

REPORT AND RECOMMENDATION PATRICIA A. SULLIVAN, United States Magistrate Judge. Now pending before the Court is Defendants’ motion for sanctions pursuant to Fed. R. Civ. P. 37(b)(2). ECF No. 60/82.1 Defendants move to dismiss based on the failure of pro se Plaintiffs Joshua Mello and Rachel Ware to comply with the Court’s January 29, 2025, discovery order requiring them to produce healthcare information and records. For the reasons that follow, I recommend that, to the extent that the motion seeks the remedy of dismissal, it should be

1 This report and recommendation is issuing in two related cases, 23-cv-479JJM and 23-cv-480JJM. The two cases are consolidated and differ principally in that only Plaintiff Joshua Mello is prosecuting the claim in 23-cv-479JJM, while he is joined by his wife, Plaintiff Rachel Ware, as co-Plaintiff in 23-cv-480JJM, as well as that the ECF docketing numbers do not align because 23-cv-480JJM has had more filings. In the interest of efficiency, only one version of this report and recommendation is being issued. Thus, to the extent that 23-cv-479JJM is considered, references to “Plaintiffs” may be interpreted as referring only to Plaintiff Mello. ECF references citing to identical filings in both cases contain, first, the docket number in 23-cv-479JJM and, second, the docket number in 23-cv- 480JJM. denied, but, to the extent that the motion seeks lesser sanctions based on the intentional failure to comply with the order to provide discovery, it should be granted. I. Standard of Review A “party who flouts a court order does so at its own peril.” Hooper-Haas v. Ziegler Holdings, LLC, 690 F.3d 34, 37 (1st Cir. 2012). Fed R. Civ. P. 37(b)(2)(A) provides that the

Court may order the imposition of sanctions for the failure to obey a discovery order. Id. In imposing such sanctions, the Rule directs that the Court may “issue further just orders” ranging from outright dismissal to a preclusion order “prohibiting the disobedient party from supporting . . . designated claims . . . or from introducing designated matters in evidence” or an instruction to the jury that a designated fact may be taken as established. Fed. R. Civ. P. 37(b)(2)(A)(i), (ii), (v). Fed. R. Civ. P. 37(b) provides the court with a “veritable arsenal of [available] sanctions in the context of discovery – including directing that the alleged facts be admitted, prohibiting the non-complying party from supporting or opposing claims or defenses [and] striking pleadings in whole or in part.” Summitbridge Credit Investments, III, LLC v. Hunt Marine I, LLC, C.A. No.

13-139-ML, 2014 WL 551051, at *1 (D.R.I. Feb. 10, 2014) (internal quotation marks omitted). When noncompliance with a discovery order occurs, “the ordering court should consider the totality of events and then choose from the broad universe of available sanctions in an effort to fit the punishment to the severity and circumstances of the violation.” Young v. Gordon, 330 F.3d 76, 81 (1st Cir. 2003). The First Circuit has set out a non-exhaustive list of factors to consider when reviewing whether Fed. R. Civ. P. 37 sanctions are appropriate and what sanction should be imposed. Sein v. Santamaria-Torres, Civil No. 21-1365 (HRV), 2024 WL 3495898, at *6 (D.P.R. July 22, 2024) (citing Vallejo v. Santini-Padilla, 607 F.3d 1, 8 (1st Cir. 2010)). These include “the severity of the discovery violations, the legitimacy of the party’s excuse for failing to comply, repetition of violations, deliberateness of the misconduct, mitigating excuses, prejudice to the other party and to the operations of the court, and adequacy of lesser sanctions.” Id. (internal quotation marks omitted). Procedurally, the First Circuit also directs courts to consider whether the offending party had notice of the possibility of sanctions and an opportunity to explain the misconduct and argue against the imposition of any sanction. Id. at *7. The

choice of sanction lies within the district court’s discretion. AngioDynamics, Inc. v. Biolitec AG, 780 F.3d 429, 435 (1st Cir. 2015). In choosing what sanction is appropriate, the “First Circuit has cautioned that dismissal with prejudice is a harsh sanction, which should be employed only when a plaintiff’s misconduct has been extreme and only after the district court has determined that none of the lesser sanctions available to it would truly be appropriate.” Reardon v. Lowe’s Companies, Inc., 1:21-cv-00362- LEW, 2024 WL 554334, at *2 (D. Me. Feb. 12, 2024) (internal quotation marks omitted), aff’d, No. 24-1269, 2025 WL 947724 (1st Cir. Jan. 22, 2025). Thus, while the most serious sanction – outright dismissal – has been deployed in response to a party’s failure to comply with a court

order compelling discovery of medical information or documents, Ford v. Kennerly, No. 17- 2457, 2018 WL 6436386, at *3-4 (6th Cir. Apr. 26, 2018); Anderson v. Huss, Case No. 2:21-cv- 00123, 2024 WL 4480095, at *1-2 (W.D. Mich. Aug. 16, 2024), adopted, 2024 WL 4343454 (W.D. Mich. Sept. 30, 2024), courts facing such circumstances often find the lesser sanction of preclusion to be more appropriate. See, e.g., Navarro de Cosme v. Hospital Paiva, 922 F.2d 926, 932 (1st Cir. 1991) (affirming preclusion of deposition of physician as sanction for failure to comply with court order compelling production of medical records); Hernandez v. R&B Power, Inc., Civil No.:15-1788 (MEL), 2017 WL 5499773, at *9-12 (D.P.R. Nov. 16, 2017) (preclusion order barring plaintiff who refused to comply with order to produce medical records from seeking compensatory damages for pain and suffering and from testifying at trial as to pain and suffering); Karlik v. Colvin, No. 12-cv-14879, 2014 WL 2095352, at *1-2 (E.D. Mich. May 20, 2014) (granting defendants’ motion to exclude medical-based damages evidence at trial where, despite production of some medical records, plaintiff failed to comply with court order to provide medical release). When lesser sanctions would adequately allay the prejudice to

defendant while otherwise allowing adjudication of the case on its merits, the court should choose the sanction that is commensurate with the infraction. See Sein, 2024 WL 3495898, at *7 (finding that lack of deliberateness renders dismissal too harsh and ordering that plaintiff “shall be allowed to testify about her emotional suffering but is precluded from testifying about, or introducing any evidence of, the psychiatric treatment”). While the court must always use leniency when considering the filings of pro se litigants, a plaintiff’s pro se status is not a basis on which to excuse noncompliance with a court order or the Rules of Civil Procedure. See Instituto de Educacion Universal Corp. v.

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Related

Vallejo v. Santini-Padilla
607 F.3d 1 (First Circuit, 2010)
Young v. Gordon
330 F.3d 76 (First Circuit, 2003)
Maria R. Navarro De Cosme v. Hospital Pavia
922 F.2d 926 (First Circuit, 1991)
Hooper-Haas v. Ziegler Holdings, LLC
690 F.3d 34 (First Circuit, 2012)
AngioDynamics, Inc. v. Biolitec AG
780 F.3d 429 (First Circuit, 2015)
Santos-Santos v. Torres-Centeno
842 F.3d 163 (First Circuit, 2016)
Brenner v. Williams-Sonoma, Inc.
867 F.3d 294 (First Circuit, 2017)
Duarte v. St. Barnabas Hosp.
341 F. Supp. 3d 306 (S.D. Illinois, 2018)
Scott v. IBM Corp.
196 F.R.D. 233 (D. New Jersey, 2000)

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Bluebook (online)
Mello v. Arruda, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mello-v-arruda-rid-2025.