Mitchell v. Nye County, Nevada

CourtDistrict Court, D. Nevada
DecidedFebruary 27, 2023
Docket2:20-cv-00086
StatusUnknown

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

Bluebook
Mitchell v. Nye County, Nevada, (D. Nev. 2023).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 KARL MITCHELL and KAYLA Case No.: 2:20-cv-00086-APG-VCF MITCHELL, 4 Order (1) Granting in Part and Denying in Plaintiffs Part Defendants’ Motion for Summary 5 Judgment; (2) Denying Plaintiffs’ Motions v. for Summary Judgment and to Extend 6 Time; (3) Denying Defendants’ Motions to NYE COUNTY, NEVADA, et al., Dismiss, to Strike, and for Leave to File 7 Supplemental Documents; and Defendants (4) Dismissing Count IX without Prejudice 8 [ECF Nos. 105, 112, 113, 119, 121, 122, 126] 9

10 Karl and Kayla Mitchell sue Nye County and current or former county employees Susan 11 Ryhal, Sharon Wehrly, and Harry Williams. The Mitchells allege the defendants violated state 12 and federal law when the Mitchells attempted to secure permits required to house tigers in Nye 13 County. 14 The parties are familiar with the facts, so I repeat them only as necessary to resolve the 15 various pending motions. I grant the defendants’ motion for summary judgment except for the 16 defamation claim against Ryhal, which I dismiss without prejudice so the Mitchells can pursue 17 that claim in state court if they choose. I deny all other pending motions. 18 I. MOTIONS TO DISMISS 19 The defendants request case-terminating sanctions because of the Mitchells’ alleged 20 discovery misconduct. They assert that the Mitchells lied at their depositions and that Karl 21 Mitchell used abusive language and abandoned his deposition. The Mitchells deny that they lied 22 or that Karl acted in bad faith during discovery. 23 1 A district court may dismiss a case with prejudice under Federal Rule of Civil Procedure 2 37 or the court’s inherent powers. Anheuser-Busch, Inc. v. Nat. Beverage Distribs., 69 F.3d 337, 3 348 (9th Cir. 1995). A terminating sanction “is very severe.” Conn. Gen. Life Ins. Co. v. New 4 Images of Beverly Hills, 482 F.3d 1091, 1096 (9th Cir. 2007). “Only willfulness, bad faith, and

5 fault justify terminating sanctions.” Id. (quotation omitted). I analyze five factors to decide 6 whether to order terminating sanctions: “(1) the public’s interest in expeditious resolution of 7 litigation; (2) the court’s need to manage its dockets; (3) the risk of prejudice to the party seeking 8 sanctions; (4) the public policy favoring disposition of cases on their merits; and (5) the 9 availability of less drastic sanctions.” Anheuser-Busch, 69 F.3d at 348 (quotation omitted). The 10 fifth factor has three subparts: (1) whether the court considered lesser sanctions; (2) whether it 11 tried those sanctions; and (3) whether it warned the recalcitrant party about the possibility of 12 case-dispositive sanctions. Id. at 352. But these factors are not conditions precedent, and “[t]he 13 most critical factor to be considered . . . is whether a party’s discovery violations make it 14 impossible for a court to be confident that the parties will ever have access to the true facts.”

15 Conn. Gen. Life Ins. Co., 482 F.3d at 1097 (quotation omitted). 16 Dismissal with prejudice is not appropriate here. Even if the Mitchells lied at their 17 depositions, that goes to their credibility and does not merit dismissal. Further, less severe 18 remedies (such as a narrow reopening of discovery) are available to rectify any prejudice to the 19 defendants caused by Karl’s behavior. The Mitchells’ conduct is not sufficiently severe to 20 terminate this case without a warning and an attempt at lesser sanctions. Thus, I deny the 21 defendants’ motions to dismiss. ECF Nos. 105, 113. The additional evidence and briefing the 22 defendants seek to file would not impact my decision, so I deny their motion for leave to file 23 those documents. ECF No. 112. 1 II. MOTION FOR EXTENSION OF TIME 2 The Mitchells move for an extension of the deadline to oppose the defendants’ motion for 3 summary judgment. They argue they need extra time because they have a pending public 4 records request for defendant Williams’ employment records and they did not have “adequate

5 time to collect discovery.” ECF No. 122 at 1-2. The defendants oppose because the Mitchells do 6 not explain why the records are relevant and why they did not obtain them during discovery. 7 The Mitchells do not identify which Federal Rule of Civil Procedure they move under, 8 but a party can secure a continuance of a motion for summary judgment if it “shows by affidavit 9 or declaration that, for specified reasons, it cannot present facts essential to justify its 10 opposition.” Fed. R. Civ. P. 56(d). The party “must show that: (1) it has set forth in affidavit 11 form the specific facts it hopes to elicit from further discovery; (2) the facts sought exist; and 12 (3) the sought-after facts are essential to oppose summary judgment.” Stevens v. Corelogic, Inc., 13 899 F.3d 666, 678 (9th Cir. 2018) (simplified). “[T]he evidence sought must be more than the 14 object of pure speculation,” and the party seeking the continuance “must state what other specific

15 evidence it hopes to discover and the relevance of that evidence to its claims.” Id. (simplified). I 16 also may extend a response deadline for “good cause” under Fed. R. Civ. P. 6(b)(1). 17 The Mitchells have not met Rule 56(d)’s requirements. They submitted a declaration 18 from Karl, but he does not identify the specific facts sought nor explain why those facts are 19 essential to oppose the summary judgment motion. Discovery was open for two and a half years 20 and closed on August 29, 2022. ECF Nos. 37; 101 at 3. The Mitchells did not move to extend 21 discovery before the deadline expired and they do not elaborate on their allegation that the length 22 of discovery was inadequate. They do not clearly explain the purpose of obtaining Williams’ 23 1 records, nor do they explain why they did not seek them until after discovery closed.1 I thus 2 deny their motion under Rules 56(d) and 6(b)(1). ECF No. 122. 3 III. MOTIONS FOR SUMMARY JUDGMENT 4 I grant a motion for summary judgment if “there is no genuine dispute as to any material

5 fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A fact is 6 material if it may affect the case outcome under the governing law. Anderson v. Liberty Lobby, 7 Inc., 477 U.S. 242, 248 (1986). A dispute is genuine when the evidence is sufficient for a 8 reasonable jury to return a verdict for the nonmoving party. Id. The moving party bears the 9 initial burden of explaining the basis for its motion and identifying the portions of the record that 10 demonstrate the absence of a genuine issue of material fact. Celotex Corp. v. Catrett, 477 U.S. 11 317, 323 (1986). If it meets its burden, the burden shifts to the nonmoving party to “produce 12 evidence of a genuine dispute of material fact that could satisfy its burden at trial.” Sonner v. 13 Schwabe N. Am., Inc., 911 F.3d 989, 992 (9th Cir. 2018). I view the evidence and reasonable 14 inferences in the light most favorable to the non-moving party. Zetwick, 850 F.3d at 440-41.

15 The defendants timely moved for summary judgment on all the Mitchells’ claims. ECF 16 No. 119.

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

Related

Nicchia v. New York
254 U.S. 228 (Supreme Court, 1920)
Monell v. New York City Dept. of Social Servs.
436 U.S. 658 (Supreme Court, 1978)
Penn Central Transportation Co. v. New York City
438 U.S. 104 (Supreme Court, 1978)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Felder v. Casey
487 U.S. 131 (Supreme Court, 1988)
Lucas v. South Carolina Coastal Council
505 U.S. 1003 (Supreme Court, 1992)
Lingle v. Chevron U. S. A. Inc.
544 U.S. 528 (Supreme Court, 2005)
Gerhart v. Lake County, Mont.
637 F.3d 1013 (Ninth Circuit, 2011)
Bingham v. Holder
637 F.3d 1040 (Ninth Circuit, 2011)
Koontz v. St. Johns River Water Management Dist.
133 S. Ct. 2586 (Supreme Court, 2013)
Theodore Heinemann, I v. Daniel Satterberg
731 F.3d 914 (Ninth Circuit, 2013)
Circus Circus Hotels, Inc. v. Witherspoon
657 P.2d 101 (Nevada Supreme Court, 1983)
Applied Information Sciences Corp. v. eBay, Inc.
511 F.3d 966 (Ninth Circuit, 2007)
Clark v. Robison
944 P.2d 788 (Nevada Supreme Court, 1997)

Cite This Page — Counsel Stack

Bluebook (online)
Mitchell v. Nye County, Nevada, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mitchell-v-nye-county-nevada-nvd-2023.