Oldridge v. Wichita, Kansas, City of

District Court, D. Kansas·Decided August 5, 2025·No. 6:21-cv-01284·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS LANCE OLDRIDGE,

Plaintiff, v. Case No. 21-1284-EFM CITY OF WICHITA, KANSAS, ROBERT LAYTON, and ANNA HATTER, Defendants.

MEMORANDUM AND ORDER Before the Court is Plaintiff Lance Oldridge’s Motion for Review of Discovery Order (Doc. 142). Plaintiff contends that Magistrate Judge Brooks G. Severson erred in denying his Amended Motion to Compel. For the reasons stated below, the Court affirms the discovery order. I. Factual and Procedural Background1 On December 1, 2021, Plaintiff commenced this action against Defendants City of Wichita, Kansas, Robert Layton, Anna Hatter, and other individuals later dismissed from the suit. As the suit stands now, Plaintiff alleges a First Amendment retaliation claim and Title VII and Kansas

Act Against Discrimination race discrimination and retaliation claims. In 2019, a news article was published that included excerpts from a deposition of Gordan Ramsay, Wichita Police Department (“WPD”) chief at the time. The excerpts covered his concern for some officers’ questionable practices and his subsequent reassignment of those officers. No

1 The facts in this section are taken from the Magistrate Judge’s Order and Memorandum. names were given in the excerpts of Ramsay’s deposition, but Plaintiff was an officer that was reassigned. After publication of the article, Ramsay publicly stated that no WPD officer had committed any legal or policy violations. Plaintiff, upset over Ramsay’s apparent contradiction, reported it to the district attorney for prosecution. The district attorney concluded that Ramsay’s conduct was not criminal in response

to Plaintiff’s report. And so, Plaintiff took his case to the sheriff for investigation. But the sheriff also refused to investigate the matter and then told Ramsay of Plaintiff’s allegations. Ramsay referred Plaintiff’s behavior to his deputies Wanda Givens, Jose Salcido, and Defendant Hatter. After their investigation, Hatter recommended firing Plaintiff, and the city manager, Defendant Layton, approved that recommendation. The stated reasons for Plaintiff’s termination were his derogatory and debasing statements about the chief to his coworkers, dishonesty, and breach of a confidentiality agreement. This case has a lengthy procedural history, but now Plaintiff seeks to compel discovery on requests for production (“RFPs”) 16, 17, 18, 19, 21, 23, and 29 as contained in Exhibit A of the

Amended Motion to Compel. Magistrate Judge Severson denied these requests for their overbreadth and irrelevance, but Plaintiff disputes the ruling and seeks its review. II. Legal Standard Upon objection to a magistrate judge’s order on a non-dispositive matter, the district court may modify or set aside any portion of the order that it finds to be “clearly erroneous or contrary to law.”2 “To be clearly erroneous, a decision must strike [the Court] as more than just maybe or probably wrong.”3 The Court does not conduct a de novo review when reviewing factual findings

2 28 U.S.C. § 636(b)(1)(A); First Union Mortg. Corp. v. Smith, 229 F.3d 992, 995 (10th Cir.2000); Fed. R. Civ. P. 72(a). 3 Parts & Elec. Motors, Inc. v. Sterling Elec., 866 F.2d 228, 236 (7th Cir. 1988). but applies a more deferential standard that requires the moving party to show that the magistrate judge’s order is clearly erroneous.4 In contrast, the “contrary to law” standard permits independent review of legal matters.5 But because a magistrate judge has broad discretion in resolving non- dispositive discovery matters, the Court is required to affirm the magistrate judge’s order unless the entire evidence leaves it “with the definite and firm conviction that a mistake has been

committed.”6 III. Analysis A. RFPs 19 & 23 The Magistrate Judge denied Plaintiff’s motion to compel RFPs 19 and 23 because of their overbreadth. RFP 19 requests “all documents related to any investigation” concerning 22 individuals. And RFP 23 requests “documents related to any suspensions, discipline, counseling, warnings, terminations, and/or promotions” for the same 22 individuals. The Magistrate Judge reasoned that the requests are facially overbroad, because they “are not narrowly tailored, contain no temporal limitation, and make no attempt to limit” the documents that Plaintiff seeks. The Magistrate Judge relies on Sonnino v. Univ. of Kan. Hosp. Auth.7 in holding that these RFPs are overbroad; Plaintiff contends that Sonnino supports his motion to compel.

In Sonnino, that Magistrate Judge explained that “omnibus terms”—like “relating to” and “concerning”—usually render an RFP facially overbroad.8 However, as Sonnino elaborates, when

4 See Burton v. R.J. Reynolds Tobacco Co., 177 F.R.D. 491, 494 (D. Kan. 1997). 5 McCormick v. City of Lawrence, 2005 WL 1606595, at *2 (D. Kan. July 8, 2005). 6 Ocelot Oil Corp. v. Sparrow Indus., 847 F.2d 1458, 1464 (10th Cir.1988) (quoting United States v. Gypsum Co., 333 U.S. 364, 395 (1948)); see also Smith v. MCI Telecomm. Corp., 137 F.R.D. 25, 27 (D. Kan. 1991) (holding that district courts generally defer to the magistrate judge and overrule orders only for a clear abuse of discretion). 7 221 F.R.D. 661 (D. Kan. 2004). 8 Id. at 667 (citing Aikens v. Deluxe Fin. Servs., Inc., 217 F.R.D. 533, 538 (D. Kan. 2003)). an omnibus term “modifies a specific type of document or specific event, rather than a large category or all documents or events, the request is not deemed overly broad on its face.”9 Plaintiff contends that these RFPs are limited to the 22 individuals he names rather than all documents related to any investigation. However, even with that stated limitation, one could determine, without clear error or contrariety to the law, that these RFPs are requests of an improperly “large

category” of documents instead of a sufficiently “specific type” of document. As such, the Court affirms the Magistrate Judge’s denial of Plaintiff’s motion to compel as it relates to RFPs 19 and 23. B. RFPs 11, 16, 17, 18, 21 & 29 RFPs 11, 16, 17, 18, 21, and 29 are Plaintiff’s attempts at discovering information about his proposed comparators. Because Plaintiff is alleging discrimination claims, he can prevail by proposing comparators.10 Plaintiffs can use an employer’s disparate treatment between comparators to establish pretext in a discrimination case.11 Here, the Magistrate Judge held these attempts at gathering comparator information as irrelevant and thus not discoverable. Plaintiff contests the rulings as to each RFP.

A comparator is an individual that is similarly situated to the plaintiff.12 “Individuals are considered ‘similarly[ ]situated’ when they deal with the same supervisor, are subjected to the same standards governing performance evaluation and discipline, and have engaged in conduct of

9 Id. at 667-68 (citing W. Res., Inc. v. Union Pac. R.R. Co., 2001 WL 1718368, at *3). 10 Swackhammer v. Sprint/United Management Co., 493 F.3d 1160, 1167-68 (10th Cir. 2007) (citing Kendrick v. Penske Transp. Services, Inc., 220 F.3d 1220, 1230 (10th Cir. 2000)). 11 Id. 12 Id.

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Related

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333 U.S. 364 (Supreme Court, 1948)
Kendrick v. Penske Transportation Services, Inc.
220 F.3d 1220 (Tenth Circuit, 2000)
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472 F.3d 736 (Tenth Circuit, 2006)
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493 F.3d 1160 (Tenth Circuit, 2007)
Ocelot Oil Corporation v. Sparrow Industries
847 F.2d 1458 (Tenth Circuit, 1988)
Aikens v. Deluxe Financial Services, Inc.
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Edgewater Hospital, Inc. v. Bowen
866 F.2d 228 (Seventh Circuit, 1988)
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Snowden v. Connaught Laboratories, Inc.
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177 F.R.D. 491 (D. Kansas, 1997)