Spiers v. City and County of San Francisco

CourtDistrict Court, N.D. California
DecidedMarch 1, 2022
Docket3:20-cv-01357
StatusUnknown

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

Bluebook
Spiers v. City and County of San Francisco, (N.D. Cal. 2022).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 DACARI SPIERS, Case No. 20-cv-01357-JSC

8 Plaintiff, ORDER RE: PLAINTIFF’S MOTION 9 v. FOR SANCTIONS

10 CITY AND COUNTY OF SAN Re: Dkt. No. 96 FRANCISCO, et al., 11 Defendants.

12 13 On August 10, 2021, the parties reached a settlement in principle, pending approval by the 14 San Francisco Board of Supervisors.1 (Dkt. No. 92; see Dkt. No. 94 at 2.)2 On December 22, 15 2021, Plaintiff filed the instant motion for sanctions. (Dkt. No. 96.) Following a Case 16 Management Conference, the Court ordered Defendants to provide a status report on the issues 17 raised in Plaintiff’s motion. (Dkt. Nos. 100, 103; see Dkt. No. 105.) After carefully considering 18 the parties’ briefing, the Court concludes that oral argument is unnecessary, see N.D. Cal. Civ. 19 L.R. 7-1(b), VACATES the March 3, 2022 hearing, and GRANTS the motion in PART as set 20 forth below. 21 BACKGROUND 22 Plaintiff’s counsel also represents the plaintiff in a related case, Richard v. City and County 23 of San Francisco, Case No. 3:20-cv-04276-JSC. On December 14, 2021, Plaintiff’s counsel 24 deposed Lieutenant Brendan O’Connor in the related case. (Dkt. No. 96-1 ¶ 2.) Lieutenant 25 26 1 All parties have consented to the jurisdiction of a magistrate judge pursuant to 28 U.S.C. § 27 636(c). (Dkt. Nos. 11, 13.) 1 O’Connor testified about evidence that was never produced in this case: interviews by Lieutenant 2 O’Connor of Officers Stangel, Martinez, and Cabillo, recorded the day after the incident; text 3 messages; and emails. (Dkt. No. 96-1 ¶¶ 2–3; Dkt. No. 98-1 ¶ 8; Dkt. No. 98-3 ¶ 2.) When 4 Plaintiff’s counsel asked why the evidence had not been produced, Defendants’ counsel 5 maintained that it had been; later, however, Defendants’ counsel agreed that the evidence had 6 never been produced. (Dkt. No. 96-1 ¶ 4; Dkt. No. 98-1 ¶¶ 5–6.) Following the deposition, 7 Plaintiff’s counsel emailed Defendants’ counsel and requested the evidence be produced. (Dkt. 8 No. 96-1 ¶ 5.) On December 16, 2021, counsel met and conferred and Plaintiff’s counsel again 9 requested the evidence. (Id. ¶ 6.) 10 Defendants explain that the interviews of Officer Stangel, Martinez, and Cabillo were part 11 of a confidential San Francisco Police Department Investigative Services Detail (“SFPD ISD”) 12 and San Francisco District Attorney’s Office Independent Investigations Bureau (“SFDA IIB”) 13 file. (Dkt. No. 98-1 ¶ 4; Dkt. No. 98-3 ¶¶ 2–3.) An SFPD representative attests:

14 As a matter of practice, SFPD does not disclose records contained in open SFPD ISD investigations because disclosure of those records 15 may negatively impact the pending criminal investigation or any pending related matters brought by SFDA IIB. SFPD ISD closes its 16 investigations once all proceedings related to the case have concluded. 17 18 (Dkt. No. 98-3 ¶ 4.) Per the policy, “SFPD ISD did not disclose any of the contents of the SFPD 19 ISD file,” including the interviews, “to the City Attorney’s Office during the course of discovery.” 20 (Id. ¶ 5; Dkt. No. 98-1 ¶ 4.) As for the text messages, SFPD solicited documents from Lieutenant 21 O’Connor on July 14, 2021. (Dkt. No. 98-3 ¶ 7.) Lieutenant O’Connor responded the next day, 22 but SFPD did not forward the text messages to Defendants’ counsel because it prioritized other 23 litigation after the parties reached a settlement in principle in August 2021. (Id. ¶¶ 8–9.) 24 Defendants’ counsel obtained the interviews and the text messages for the first time after 25 Lieutenant O’Connor’s deposition. (Dkt. No. 98-1 ¶ 4–6.) Defendants’ counsel produced the text 26 messages to Plaintiff on December 16, 2021, and the interviews on January 4, 2022. (Id. ¶¶ 5–6.) 27 DISCUSSION 1 is well settled” that a district court considering sanctions “may, in its informed discretion, rely on 2 inherent power rather than the federal rules or § 1927.” Fink v. Gomez, 239 F.3d 989, 994 (9th 3 Cir. 2001). Under 28 U.S.C. § 1927, the Court may require an attorney or litigant “who so 4 multiplies the proceedings in any case unreasonably and vexatiously . . . to satisfy personally the 5 excess costs, expenses, and attorneys’ fees reasonably incurred because of such conduct.” 28 6 U.S.C. § 1927; see Wages v. I.R.S., 915 F.2d 1230, 1235–36 (9th Cir. 1990) (explaining that 7 Section 1927 sanctions can be imposed against unrepresented litigants as well as attorneys). 8 Given that Defendants’ counsel himself was not aware of the evidence until the December 14, 9 2021 deposition and thereafter worked quickly to produce the evidence, the Court finds that 10 sanctions are only potentially appropriate against Defendants. 11 Courts have “inherent authority to impose sanctions for bad faith, which includes a broad 12 range of willful improper conduct.” Fink, 239 F.3d at 992. “[S]anctions are available if the court 13 specifically finds bad faith or conduct tantamount to bad faith.” Id. at 994. Conduct tantamount 14 to bad faith may include “recklessness when combined with an additional factor such as 15 frivolousness, harassment, or an improper purpose.” Id. 16 The Court finds that Defendant the City and County of San Francisco, acting through 17 SFPD, engaged in conduct tantamount to bad faith. There is no dispute that Defendant did not 18 disclose the evidence to their own counsel until the December 14, 2021 deposition. And the 19 failure to disclose was not inadvertent; it was part of an admitted SFPD policy. As such, 20 Defendant was at least reckless as to its obligations under the discovery rules. See Milke v. City of 21 Phoenix, No. CV-15-00462-PHX-ROS, 2019 WL 11766079, at *12 (D. Ariz. July 19, 2019) 22 (“[Plaintiff] did not produce the book in her first responses to the request for production . . . . 23 [She] had no good faith basis for failing to include [it].”). Moreover, the recklessness is combined 24 with the additional factor of an improper purpose. Protecting the integrity of a criminal 25 investigation might be a proper basis to quash or modify a discovery request or to enter a 26 protective order, (e.g., Dkt. No. 69), but it is an improper purpose for refusing to disclose to 27 counsel, Plaintiff, and the Court that discoverable evidence exists at all. See N. Am. Watch Corp. 1 power supported sanctions award, where “appellants represented to the court that they did not 2 have the documents in question” but later produced them). 3 Defendants argue there is no prejudice to Plaintiff because the evidence was produced 4 within three weeks of the deposition and because Plaintiff still wants to proceed with the agreed 5 upon settlement. But Plaintiff’s counsel had a professional obligation to make sure Defendants 6 actually produced the evidence and to review it, lest it change Plaintiff’s settlement position. 7 “Litigation cannot work if a party is free to withhold responsive documents . . . and [later] . . . 8 simply state additional discovery can cure any prejudice.” Milke, 2019 WL 11766079, at *15; see 9 Henry v. Gill Indus., Inc., 983 F.2d 943, 947 (9th Cir. 1993) (“[Plaintiff] argues that his failure to 10 produce these documents caused [Defendant] no prejudice, but this, even if true, would not 11 establish that his conduct did not violate the discovery rules.”).

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Spiers v. City and County of San Francisco, Counsel Stack Legal Research, https://law.counselstack.com/opinion/spiers-v-city-and-county-of-san-francisco-cand-2022.