Petersen, Richard v. Hormel Foods Corporation

CourtDistrict Court, W.D. Wisconsin
DecidedJanuary 15, 2025
Docket3:24-cv-00137
StatusUnknown

This text of Petersen, Richard v. Hormel Foods Corporation (Petersen, Richard v. Hormel Foods Corporation) is published on Counsel Stack Legal Research, covering District Court, W.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Petersen, Richard v. Hormel Foods Corporation, (W.D. Wis. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WISCONSIN

RICHARD PETERSEN, et al.,

Plaintiffs, v. OPINION and ORDER

HORMEL FOODS COPORATION 24-cv-137-jdp and JENNIE-O TURKEY STORE, INC., et al.,

Defendants.

In this personal injury case, plaintiff Richard Petersen is suing defendants Hormel Foods Corporation and Jennie-O Turkey Store, Inc. for alleged injuries he sustained during a chemical delivery to one of defendants’ feed mills. Previously in this case, the court ordered in camera review of documents defendants withheld based on claims of privilege or work-product protection. Dkt. 79. The court has reviewed the documents and finds that defendants have largely failed to support these claims. Accordingly, the court ORDERS defendants to produce in full every document listed in their fourth amended privilege log, Dkt. 75-1, other than HORMEL000627-629, which is privileged, and HORMEL000630-631, 632-633, 634-635, 636-637, 638-644, 645-648, 649-650, 651, and 652-656, which must be produced, except their final emails may be withheld. BACKGROUND On October 31, 2022, plaintiff delivered a shipment of liquid lysine to one of defendants’ facilities. Dkt. 29 at 3. According to plaintiff, he was directed to unload the lysine into the wrong tank, which mixed with the contents of that tank and produced a noxious gas that injured him. Id. at 3–4. Plaintiff filed this lawsuit claiming common law negligence and statutory failure to maintain a safe work environment. Id. at 4–5. Discovery commenced, and plaintiff moved to compel the discovery of certain documents defendants had withheld as privileged or protected work-product. Dkt. 36. The

court granted the motion in part and instructed defendants to supplement their privilege log with necessary information and reevaluate their claims of privilege for compliance with the legal standards outlined in the court’s opinion. Dkt. 69 at 7. Defendants produced a second, and then a third, amended privilege log, after which plaintiff filed a motion to enforce the court’s discovery order, claiming, among other things, that these iterations still fell short. Dkts. 71, 72 at 2. In response, defendants produced a fourth amended privilege log, Dkt. 75- 1, which they argued fully complied with the court’s order. Dkt. 74 at 2. The court ordered in camera review of the all the documents listed in the fourth amended

privilege log and invited defendants to submit any additional explanation or sworn testimony to support withholding the documents. Dkt. 79. Defendants timely submitted the materials for in camera review, Dkt. 84, and filed a short brief with some additional argument, Dkt. 82.

LEGAL STANDARDS When a party withholds information otherwise discoverable by claiming that the information is privileged or subject to protection, the party must: (1) expressly make the claim, and (2) describe the nature of the documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable other parties and

the court to assess the claim. Fed. R. Civ. P. 26(b)(5)(A). The party resisting discovery bears the burden of showing that the withheld documents are in fact privileged or protected. United States v. White, 950 F.2d 426, 430 (7th Cir. 1991). A. Attorney-client Privilege “The attorney-client privilege protects communications made in confidence by a client

and a client’s employees to an attorney, acting as an attorney, for the purpose of obtaining legal advice.” Sandra T.E. v. S. Berwyn Sch. Dist. 100, 600 F.3d 612, 618 (7th Cir. 2010) (citations omitted). The privilege adheres “only if [the communications] constitute legal advice or tend directly or indirectly to reveal the substance of a client confidence.” United States v. Defazio, 899 F.2d 626, 635 (7th Cir. 1990). Additionally, the attorney-client privilege only shields communications that were intended to be confidential, so communications made to an attorney in the presence of a third party or made with the intent that they will be disclosed to a third party are not privileged. United States v. Evans, 113 F.3d 1457, 1462 (7th Cir. 1997);

United States v. White, 950 F.2d 426, 430 (7th Cir. 1991). The Seventh Circuit has adopted Professor Wigmore's formulation of the attorney- client privilege: (1) Where legal advice of any kind is sought (2) from a professional legal adviser in his capacity as such, (3) the communications relating to that purpose, (4) made in confidence (5) by the client, (6) are at his instance permanently protected (7) from disclosure by himself or by the legal adviser, (8) except [if] the protection [is] waived. Evans, 113 F.3d at 1461. “The party seeking to invoke the privilege bears the burden of proving all of its essential elements,” id., and “each of these elements must be established as to each document, as the mere existence of an attorney-client relationship is not sufficient to cloak all communications with the privilege.” Allendale Mut. Ins. Co. v. Bull Data Sys., Inc., 145 F.R.D. 84, 86 (N.D. Ill. Nov. 10, 1992). B. Work Product The work-product doctrine gives qualified protection to documents prepared in anticipation of litigation. Binks Mfg. Co. v. National Presto Indus., Inc., 709 F.2d 1109, 1118 (7th Cir. 1983). If a document that was prepared in anticipation of litigation serves another

business purpose as well, it is still protected work product only if “the primary motivating purpose behind [its] creation” is “to aid in possible future litigation.” Id. at 1119. By contrast, “[m]aterials created in the ordinary course of business which may have the incidental effect of being helpful in litigation” are not protected work product. Lynk Labs, Inc. v. Juno Lighting LLC, No. 15 C 4833, 2016 WL 6135711, at *2 (N.D. Ill. Oct. 21, 2016) (citation omitted); see also Logan v. Com. Union Ins. Co., 96 F.3d 971, 976–77 (7th Cir. 1996) (“[W]e look to whether in light of the factual context ‘the document can fairly be said to have been prepared or obtained because of the prospect of litigation.’” (quoting Binks, 709 F.2d at 1119) (emphasis in Binks)).

Unlike the attorney-client privilege, a party may discover certain documents protected by the work-product doctrine by showing “substantial need” and inability to obtain equivalent information “without undue hardship.” Fed. R. Civ. P. 26(b)(3). “Opinion” work product, however, is not discoverable. Id. Such materials include documents revealing “mental impressions, conclusions, opinions or legal theories.” Id.

ANALYSIS After reviewing the disputed documents in camera,1 the court finds only a handful contain information that falls within the ambit of attorney-client privilege or work-product

1 Defendants submitted their documents for in camera review in a batch, and this submission included some non-logged documents. For example, the batch submitted included protection. Procedurally, defendants’ privilege log remains deficient, with many entries missing key pieces of information. Additionally, several entry descriptions are incomplete, creating a misleading summary of the documents withheld.

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