Park v. State Farm Fire and Casualty Company

CourtDistrict Court, W.D. Washington
DecidedMarch 19, 2025
Docket2:23-cv-01564
StatusUnknown

This text of Park v. State Farm Fire and Casualty Company (Park v. State Farm Fire and Casualty Company) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Park v. State Farm Fire and Casualty Company, (W.D. Wash. 2025).

Opinion

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5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 ANNIE PARK, CASE NO. 2:23-cv-01564-TL 12 Plaintiff, ORDER ON RULE 26 EXPERT v. WITNESS DISCLOSURES 13 STATE FARM FIRE AND CASUALTY 14 COMPANY et al., 15 Defendants. 16

17 This matter is before the Court on Plaintiff Annie Park’s Motion for Leave to Supplement 18 Her Expert Witness Disclosures Under Rule 26. Dkt. No. 64. Plaintiff, however, did not timely 19 disclose any expert witnesses in this case. See generally Docket; cf. Dkt. No. 44 (“Defendant’s 20 Expert Witness Disclosure”). The instant motion is therefore a request for leave to make an 21 initial disclosure of an expert witness, some six months after the deadline to do so. See Dkt. 22 No. 42 (establishing September 30, 2024, as the deadline to disclose expert-witness testimony). 23 Having reviewed Plaintiff’s motion, Defendant State Farm Fire and Casualty Company’s (“State 24 Farm”) response (Dkt. No. 66), Plaintiff’s reply (Dkt. No. 67), and the relevant record, and 1 finding additional briefing unnecessary, see infra Section III.C, the Court GRANTS Plaintiff’s 2 motion, subject to sanctions to be explained in this Order. 3 I. BACKGROUND 4 A. Brief Factual Background

5 The Court assumes familiarity with the underlying facts of the case and will not detail 6 them here. In summary, this is a bad-faith insurance action. See generally Dkt. No. 1-1. Plaintiff 7 owns a residential rental property located in Lacey, Washington, that Defendant insured under a 8 rental dwelling policy. Id. ¶ 7. Plaintiff alleges that, after the property sustained damage 9 associated with methamphetamine contamination and she filed a claim, State Farm mishandled 10 the claim, resulting in the denial of coverage and insurance benefits. Id. ¶¶ 13–37. Plaintiff 11 alleges that State Farm breached the insurance contract, including the implied covenant of good 12 faith and fair dealing, as well as numerous provisions of Washington state law. Id. ¶¶ 38–70. 13 B. Relevant Procedural Background 14 On September 8, 2023, Plaintiff filed a civil action against State Farm in King County

15 Superior Court. Dkt. No. 1-1. On October 12, 2023, State Farm removed the case to federal 16 court. Dkt. No. 1. On January 19, 2024, the Court established a trial date of March 17, 2025, and 17 set attendant deadlines accordingly. Dkt. No. 14. Of particular relevance here, the Court set 18 August 19, 2024, as the deadline to disclose expert testimony Id. at 1. Throughout the pendency 19 of the case, both Parties have sought to extend the case deadlines multiple times. 20 On August 16, 2024, Plaintiff filed a motion requesting “a short extension of the 21 discovery deadlines by approximately sixty (60) days.” Dkt. No. 21 at 1. Among other things, 22 Plaintiff requested that the “[e]xpert disclosure deadline” be extended to October 18, 2024, and 23

24 1 that the deadline for filing dispositive motions be extended to January 13, 2025.1 Id. at 2. Noting 2 that Plaintiff’s request sought to extend the dispositive-motion deadline without also resetting the 3 trial date, which ran counter to this Court’s Standing Order for All Civil Cases, and noting 4 further that Plaintiff had only conferred with State Farm as to the extension of the expert-

5 disclosure deadline, the Court extended the expert-disclosure deadline by one week, to August 6 26, 2024, and declined to grant any further extensions. Dkt. No. 22. 7 On August 21, 2024, the Parties together sought to extend the case deadlines and filed a 8 stipulated motion to that effect. Dkt. No. 23. The Court, however, denied the motion, advising 9 that “the Parties have provided neither an extraordinary basis for extending the dispositive 10 motions deadline, nor have they provided their availability to allow the Court to reset the trial 11 date.” Dkt. No. 24 at 2. Both of these omissions contravened the Standing Order for All Civil 12 Cases. 13 On August 29, 2024, the Parties again sought to extend discovery-related deadlines. Dkt. 14 No. 27. This time, the Court granted the Parties’ stipulated motion and advised that it would

15 enter a new case scheduling order. See Dkt. No. 28. On September 24, 2024, the Court reset the 16 trial date to March 17, 2025, and changed the case deadlines accordingly. Dkt. No. 42. The Court 17 established September 30, 2024, as the deadline for the Parties to disclose expert testimony. Id. 18 at 1. On September 30, 2024, State Farm timely filed its disclosure of expert witnesses. Dkt. 19 No. 44. 20 The Court reset the trial date and attendant deadlines twice more, on October 16, 2024, 21 and November 15, 2024. Dkt. Nos. 47, 57. As of the date of this Order, the trial in this case is 22

23 1 Plaintiff actually requested that the deadline for dispositive motions be extended to January 13, 2024, a date that passed some seven months prior to Plaintiff’s filing of the motion. Dkt. No. 21 at 2. The Court assumed that Plaintiff 24 intended January 13, 2025. 1 scheduled to begin November 3, 2025. But the subject of the instant motion—the expert- 2 disclosure deadline—which lapsed on September 30, 2024, without Plaintiff having made any 3 such disclosures, was not, and has not been, extended. 4 On January 6, 2025, with nearly five months remaining in discovery and some six months

5 before the dispositive-motion deadline, State Farm filed a motion for partial summary judgment. 6 Dkt. No. 58. This motion is fully briefed. See Dkt. Nos. 61 (Plaintiff’s response), 65 (State 7 Farm’s reply). On February 11, 2025, during the pendency of State Farm’s motion for partial 8 summary judgment, Plaintiff filed the instant motion regarding the disclosure of expert 9 witnesses. Dkt. No. 64. On February 20, 2025, State Farm filed a response in opposition to 10 Plaintiff’s motion (Dkt. No. 66), and on February 25, 2025, Plaintiff filed a reply (Dkt. No. 67). 11 On March 5, 2025, State Farm filed a notice of its intent to file a surreply (Dkt. No. 68), and a 12 motion for leave to file a surreply (Dkt. No. 69). 13 II. LEGAL STANDARD 14 Where a party “fails to provide information . . . as required by [Federal Rule of Civil

15 Procedure] 26(a) or (e), the party is not allowed to use that information or witness to supply 16 evidence on a motion, at a hearing, or at trial, unless the failure was substantially justified or is 17 harmless.” Fed. R. Civ. P. 37(c)(1). “Rule 37(c)(1) ‘gives teeth’ to the requirements 18 of Rule 26(a)(2)(B) and affords the district court ‘particularly wide latitude . . . to issue 19 sanctions’ for a party’s failure to meet those requirements.” Mansur Props. LLC v. First Am. 20 Title Ins. Co., 635 F. Supp. 3d 1116, 1133 (W.D. Wash. 2022) (quoting Yeti by Molly, Ltd. v. 21 Deckers Outdoor Corp., 259 F.3d 1101, 1106 (9th Cir. 2001)). Although exclusion is the default 22 sanction that Rule 37(c)(1) prescribes for unjustified or harmful nondisclosure, the “particularly 23 wide latitude” afforded district courts means that it is not the only penalty available. That is, a

24 court “may impose other appropriate sanctions” in lieu of, or in addition to, exclusion. Fed. R. 1 Civ. P. 37(c)(1). Consideration of other sanctions is especially relevant where the nondisclosure 2 was “substantially justified” or “harmless.” See id.; see also Merchant v. Corizon Health, Inc., 3 993 F.3d 733, 740 (9th Cir. 2021) (“As the Rule plainly states, litigants can escape the 4 ‘harshness’ of exclusion only if they prove that the discovery violations were substantially

5 justified or harmless.” (quoting Yeti by Molly, Ltd., 259 F.3d at 1106)).

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Bluebook (online)
Park v. State Farm Fire and Casualty Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/park-v-state-farm-fire-and-casualty-company-wawd-2025.