Reliance Hospitality LLC v. ASNL Incorporated

CourtDistrict Court, D. Arizona
DecidedAugust 16, 2023
Docket2:21-cv-01970
StatusUnknown

This text of Reliance Hospitality LLC v. ASNL Incorporated (Reliance Hospitality LLC v. ASNL Incorporated) is published on Counsel Stack Legal Research, covering District Court, D. Arizona primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Reliance Hospitality LLC v. ASNL Incorporated, (D. Ariz. 2023).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Reliance Hospitality LLC, No. CV-21-01970-PHX-DJH

10 Plaintiff, ORDER

11 v.

12 ASNL Incorporated,

13 Defendant. 14 15 This matter arises out of a contract for hotel management services. Plaintiff/Counter 16 Defendant Reliance Hospitality LLC d/b/a Reliance Hotel Group (“Reliance”) has filed a 17 “Motion for Case-Ending Sanctions and Motion for Summary Judgment” (Doc. 20) against 18 Defendant/Counter Claimant ASNL, Inc. d/b/a Holiday Inn Sioux (“ASNL”).1 Reliance 19 argues it is entitled to case-ending sanctions against ASNL under Federal Rule of Civil 20 Procedure 37(d)(1)(A)(ii) because ASNL failed to respond to discovery requests. 21 Alternatively, Reliance contends it is entitled to summary judgment under Rule 562 on its 22 breach of contract claim and ASNL’s breach of contract counterclaim. The Court will 23 address each of Reliance’s requests in turn. Reliance’s Motion is denied in its entirety 24 because ASNL’s failure to respond is justified, and disputes of fact remain for trial. 25 1 The matter is briefed. ASNL filed a Response (Doc. 23) and Reliance filed a Reply 26 (Doc. 24). Reliance requested oral argument on the matter. The Court finds that the issues have been fully briefed and oral argument will not aid the Court’s decision. Therefore, 27 Reliance’s request is denied. See Fed. R. Civ. P. 78(b) (court may decide motions without oral hearings); LRCiv 7.2(f) (same). 28 2 Unless otherwise noted, all Rule references are to the Federal Rules of Civil Procedure. 1 I. Reliance’s Motion for Sanctions 2 The Court will first evaluate whether Rule 37(d) sanctions are warranted against 3 ASNL for failing to produce discovery. The Court set the deadline for completion of fact 4 discovery in this matter as September 2, 2022. (Doc. 13 at ¶ 4). Below is a timeline of the 5 parties’ discovery efforts: 6 - On March 31, 2022, ASNL notified the Court that it served Reliance its Initial Disclosure Statement under Rule 26 (Doc. 14); 7 - On March 31, 2022, Reliance notified the Court that it served ASNL 8 its Initial Disclosure Statement under Rule 26 (Doc. 15); 9 - On June 17, 2022, the parties filed a Joint Report on Settlement Talks (Doc. 19), indicating a settlement offer was under consideration and 10 that the parties expected settlement discussions to continue over the 11 course of discovery; 12 - On June 30, 2022, Reliance notified the Court that it served ASNL Non Uniform Interrogatories and Requests for Production of 13 Documents (Doc. 18); and 14 - On July 19, 2022, ASNL notified the Court that it served Reliance 15 Non Uniform Interrogatories and Requests for Production of Documents (Doc. 17). Reliance served ASNL its responses on 16 September 1, 2022. (Doc. 19). 17 At issue is ASNL’s failure to respond to the Non Uniform Interrogatories and 18 Requests for Production of Documents that Reliance sent on June 30, 2022 (the “June 30 19 Requests”), which the Court characterizes as a discovery dispute. Reliance sent the June 30 20 Requests to ASNL via email. (Doc. 20 at 5–6). Counsel for Reliance then contacted ASNL 21 on September 2, 2022, to notify ASNL its discovery responses were “more than 30 days 22 late, and ASNL’s failure to response has severely prejudiced [Reliance’s] ability to prove 23 [its] claims and defend[.]” (Id. at 6 quoting Doc. 20-1 at 60). ASNL did not respond to 24 this email until October 14, 2022. (See Doc. 20-1). Reliance now seeks case-ending 25 sanctions in the form of dismissal or default judgment. (Doc. 20 at 7–9). 26 A. Legal Standard for Sanctions under Rule 37(d) 27 Rule 37(d) permits a district court to order sanctions “if a party, after being properly 28 served with interrogatories under Rule 33 or a request for inspection under Rule 34, fails 1 to serve its answers, objections, or written response.” Fed. R. Civ. P. 37(d)(1)(A)(ii). 2 District courts enjoy “great latitude” in imposing sanctions and may take any of the 3 following actions: 4 (i) direct[] that the matters embraced in the order or other designated facts be taken as established for purposes of the action, as the 5 prevailing party claims; 6 (ii) prohibit[] the disobedient party from supporting or opposing 7 designated claims or defenses, or from introducing designated matters in evidence; 8 (iii) strik[e] pleadings in whole or in part; 9 (iv) stay[] further proceedings until the order is obeyed; 10 (v) dismiss[] the action or proceeding in whole or in part; 11 (vi) render[] a default judgment against the disobedient party; or 12 (vii) treat[] as contempt of court the failure to obey any order except an order to submit to a physical or mental examination. 13 14 Id. (d)(3) (referencing id. (b)(2)(A)(i)—(vi)); see Lew v. Kona Hosp., 754 F.2d 1420, 1425 15 (9th Cir. 1985). “Instead of or in addition to the orders above, the court must order the 16 disobedient party, the attorney advising that party, or both to pay the reasonable expenses, 17 including attorney’s fees[.]” Fed. R. Civ. P. 37(d)(3). 18 When a party fails to respond to discovery requests, sanctions are mandatory unless 19 the party’s failure to act “was substantially justified or other circumstances make an award 20 of expenses unjust.” Lee v. Walters, 172 F.R.D. 421, 425 (D. Or. 1997) 21 (citing Fed. R. Civ. P. 37(d)(3)). The party facing sanctions bears the burden of showing 22 its noncompliance was justified. See Hawk v. Bank2 & Dovenmuehle Mortg., Inc., 2016 23 WL 6662742, at *3 (D. Or. Oct. 19, 2016) (citing Hyde & Drath v. Baker, 24 F.3d 1162, 24 1171 (9th Cir. 1994)). When considering the “drastic sanctions of dismissal or default” as 25 in this case, “the range of [the district court’s] discretion is narrowed and the losing party’s 26 non-compliance must be due to willfulness, fault or bad faith.” Sigliano v. Mendoza, 642 27 F.2d 309, 310 (9th Cir. 1981) (citing Societe International v. Rogers, 357 U.S. 197, 212 28 (1958)). Neither dismissal nor default may be imposed “when failure to comply is due to 1 circumstances beyond the recalcitrant’s control.” Id. (citing United States v. Sumitomo 2 Marine & Fire Ins. Co., 617 F.2d 1365, 1369 (9th Cir. 1980)). Courts must also weigh 3 various policy factors before issuing case-ending sanctions. See Porter v. Martinez, 941 4 F.2d 732, 733 (9th Cir. 1991). 5 B. Reliance is not Entitled to Sanctions against ASNL 6 The Court finds that ASNL’s actions do not warrant case-ending sanctions under 7 Rule 37(d) because Counsel for ASNL substantially justified his failure to respond and 8 there is no evidence of bad faith. Moreover, the relevant policy factors weigh against 9 issuing sanctions. 10 1. Substantial Justification or Other Circumstances 11 First, Counsel for ASNL’s failure to respond was substantially justified. He claims 12 the June 30 Requests were not actually served because the parties did not agree to service 13 via electronic email. (Doc. 23 at 7).

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Reliance Hospitality LLC v. ASNL Incorporated, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reliance-hospitality-llc-v-asnl-incorporated-azd-2023.