(PS) James v. Sacramento County

CourtDistrict Court, E.D. California
DecidedFebruary 6, 2025
Docket2:18-cv-00180
StatusUnknown

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

Bluebook
(PS) James v. Sacramento County, (E.D. Cal. 2025).

Opinion

1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 FOR THE EASTERN DISTRICT OF CALIFORNIA 9 10 DANIEL JAMES, et al., No. 2:18-cv-0180 DAD-SCR 11 Plaintiffs, 12 v. ORDER 13 SACRAMENTO COUNTY, SACRAMENTO COUNTY SHERIFF’S 14 OFFICE, et al., 15 Defendants. 16 17 Plaintiff has filed a motion for discovery-related sanctions (“Sanctions Motion,” ECF No. 18 81) and a motion to compel production of documents and videos (“Motion to Compel,” ECF No. 19 82). The Sanctions Motion seeks $5,000 in sanctions for Defendants’ alleged failure to produce 20 all documents required under the court’s October 18, 2024 order. ECF Nos. 78, 81. The Motion 21 to Compel seeks an order requiring disclosure of additional video camera footage related to 22 Plaintiff’s arrests, unredacted versions of documents already produced in this litigation, and all 23 grievances and “kites” Plaintiff submitted while jailed by Defendants. ECF No. 82. Defendants 24 oppose both motions. The Court took both motions under submission after a hearing on January 25 23, 2025 in which Plaintiff appeared pro se and Defendants appeared through counsel. For the 26 reasons provided below, the Court now DENIES the Sanctions Motion and GRANTS IN PART 27 AND DENIES IN PART the Motion to Compel. 28 1 I. Factual and Procedural Background 2 Plaintiff’s Third Amended Complaint (“TAC”), filed June 7, 2019, asserts that he was 3 unconstitutionally arrested on August 23 and September 6-7, 2016; January 20, February 10 and 4 17, and March 22, 2017; March 6 and June 18, 2018; and April 28, 2019. ECF No. 15 at ⁋⁋ 21- 5 34. Based on these arrests, the TAC alleges eight causes of action: “assault, battery, false 6 imprisonment, violation of civil rights, and excessive force, negligence, intentional infliction of 7 emotional distress[.]” Id. at 17-20. Specifically, the TAC asserts that Defendants Sacramento 8 County, the Sacramento County Sheriff’s Office, and Sheriff Scott Jones, as policymaking 9 authorities acting under color of law, should have known based on multiple jury verdicts and 10 settlements that subordinates were inadequately trained concerning the use of unreasonable force 11 against jail inmates. Id. at ⁋⁋ 38-39. Plaintiff asserts that he was “subjected to an ongoing pattern 12 of abuse, harassment and physical assaults and batteries from the Sacramento county sheriff’s 13 office and its officers[.]” Id. at ⁋ 57. 14 On May 13, 2024, pursuant to Plaintiff’s motion to relieve his attorney, District Judge 15 Dale Drozd dismissed Plaintiff’s counsel from this case and updated the docket to reflect 16 Plaintiff’s pro se status. ECF No. 60. 17 On September 13, 2024, Plaintiff moved to compel Defendants to produce documents 18 pursuant to Plaintiff’s request for such production. ECF No. 68. The requests for production 19 (“RFP”) sought, inter alia, all records of Plaintiff’s arrests on August 23 and September 6-7, 20 2016; February 10 and March 22, 2017; March 6, 2018; and April 28, 2019. ECF No. 68 at 10- 21 11. This included any photos, audio, and videos of Plaintiff on those dates, along with grievances 22 and jail medical records when applicable. Id. 23 On October 18, 2024, the Court ordered Defendants to “to search for and produce all of 24 Plaintiff’s medical records pertaining to Plaintiff’s arrests and periods of custody that are at issue 25 in this action[,]” through subpoenas if necessary. ECF No. 78. Plaintiff, in turn, was to provide 26 any privacy waivers necessary for such production. Id. Defendants had until 30 days after 27 issuance of the order to produce those records or provide a timeline by which such production 28 would be complete. Id. As to files Defendants had previously served via flashdrive but Plaintiff 1 asserted he could not view, Defendants had agreed to share them via file transfer link. Id. The 2 Court ordered the parties to meet and confer to discuss alternative methods of production if that 3 failed. Id. 4 Defendants assert that Plaintiff delivered the required HIPAA release for his medical 5 records on October 30, 2024. ECF No. 92-1 at ⁋ 3. Counsel for Defendants forwarded the 6 release to the Sacramento County Department of Health Services’ Adult Correctional Health 7 department, which sent counsel a 61-page fax of Plaintiff’s records the next day. Id. at ⁋⁋ 3-4. 8 On November 13, 2024, Defendant’s counsel served these 61 pages on Plaintiff along with 9 supplemental responses to the RFPs. Id. at ⁋ 5; see also ECF No. 81 at 10 (supplemental 10 responses dated November 13, 2024). 11 The Court’s October 18 order also noted Plaintiff’s apparent inability to access the 12 discovery materials that Defendants had served on Plaintiff and noted Defendants’ agreement to 13 facilitate alternative access. ECF No. 78. That access now having apparently been provided, 14 Plaintiff’s Motion to Compel complains about documents and videos that he believes are missing 15 and about the redactions Defendants have made to other documents. ECF No. 82. The Court’s 16 October 18 order emphasized that the “discovery period” remains closed and that the Court would 17 not “hear further discovery disputes, with the exception of any dispute about Defendants’ 18 compliance with this Order, absent a showing of good cause and diligence.” ECF No. 78. 19 II. Legal Standard 20 The purpose of discovery is to “remove surprise from trial preparation so the parties can 21 obtain evidence necessary to evaluate and resolve their dispute.” United States v. Chapman 22 Univ., 245 F.R.D. 646, 648 (C.D. Cal. 2007) (quotation and citation omitted). Under Rule 26 of 23 the Federal Rules of Civil Procedure, “[p]arties may obtain discovery regarding any 24 nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs 25 of the case, considering the importance of the issues at stake in the action, the amount in 26 controversy, the parties’ relative access to relevant information, the parties’ resources, the 27 importance of the discovery in resolving the issues, and whether the burden or expense of the 28 proposed discovery outweighs its likely benefit. Information within this scope of discovery need 1 not be admissible in evidence to be discoverable.” Fed. R. Civ. P. 26(b)(1). “Relevance for 2 purposes of discovery is defined very broadly.” Garneau v. City of Seattle, 147 F.3d 802, 812 3 (9th Cir. 1998). However, relevance alone is not sufficient to obtain discovery— “discovery must 4 also be proportional to the needs of the case.” In re Bard IVC Filters Prods. Litig., 317 F.R.D. 5 562, 564 (D. Ariz. 2016). For example, a “party need not provide discovery of electronically 6 stored information from sources that the party identifies as not reasonably accessible because of 7 undue burden or cost.” Fed. R. Civ. P. 26(b)(2)(B). 8 Under Rule 37 of the Federal Rules of Civil Procedure, “[a] party seeking discovery may 9 move for an order compelling an answer, designation, production, or inspection.” Fed. R. Civ. P. 10 37(a)(3)(B). The court may order a party to provide further responses to an “evasive or 11 incomplete disclosure, answer, or response.” Fed. R. Civ. P. 37(a)(4).

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

Related

Avila v. Willits Environmental Remediation Trust
633 F.3d 828 (Ninth Circuit, 2011)
Laura Jepsen v. Florida Board of Regents
610 F.2d 1379 (Fifth Circuit, 1980)
William Hunt v. County of Orange
672 F.3d 606 (Ninth Circuit, 2012)
Rockwell International Corp. v. H. Wolfe Iron & Metal Co.
576 F. Supp. 511 (W.D. Pennsylvania, 1983)
Owens-Hart v. Howard University
317 F.R.D. 1 (District of Columbia, 2016)
Garneau v. City of Seattle
147 F.3d 802 (Ninth Circuit, 1998)
Alexander v. Federal Bureau of Investigation
194 F.R.D. 305 (District of Columbia, 2000)
United States ex rel. O'Connell v. Chapman University
245 F.R.D. 646 (C.D. California, 2007)
Sanchez v. City of Santa Ana
936 F.2d 1027 (Ninth Circuit, 1990)

Cite This Page — Counsel Stack

Bluebook (online)
(PS) James v. Sacramento County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ps-james-v-sacramento-county-caed-2025.