Tyler v. Chelan County

CourtDistrict Court, E.D. Washington
DecidedNovember 28, 2023
Docket2:19-cv-00172
StatusUnknown

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

Bluebook
Tyler v. Chelan County, (E.D. Wash. 2023).

Opinion

1 FILED IN THE U.S. DISTRICT COURT 2 EASTERN DISTRICT OF WASHINGTON Nov 28, 2023 3 SEAN F. MCAVOY, CLERK 4

5 UNITED STATES DISTRICT COURT

6 EASTERN DISTRICT OF WASHINGTON

7 JENNIFER TYLER, No: 2:19-CV-00172-MKD

8 Plaintiff, ORDER DENYING MOTION FOR PROTECTIVE ORDER 9 v. ECF No. 53 10 CHELAN COUNTY and CHELAN COUNTY SHERIFF’S OFFICE, 11 Defendants. 12

13 Before the Court is Defendants’ Motion for Protective Order, ECF No. 53. 14 Defendant seeks a protective order precluding discovery into certain topics. For 15 the reasons stated herein, Defendant’s motion is DENIED. 16 BACKGROUND 17 After Chelan County fired Plaintiff in 2010, the parties attended private 18 arbitration that resulted in her reinstatement. ECF No. 1 at 4 ¶ 5.1; ECF No. 53 at 19 2. Plaintiff sued Chelan County in 2013, which resulted in summary judgment on 20 1 certain claims, and a jury trial on others in March 2018. ECF No. 53 at 3-4; ECF 2 No. 56 at 4.

3 Plaintiff began the instant suit with her Complaint filed May 17, 2019. ECF 4 No. 1. Plaintiff pursues sex discrimination and retaliation claims under federal and 5 state statutes, and various theories of state law negligence. ECF No. 1 at 2 ¶ 1.1.

6 Plaintiff alleges that she was subject to harassment and retaliation following the 7 state court litigation. ECF No. 1 at 4-5 ¶¶ 5.1-5.9. On October 13, 2023, Plaintiff 8 served Defendants a Fed. R. Civ. P. 30(b)(6) notice and her third set of 9 interrogatories and requests for production. ECF Nos. 54-7, 54-8. Defendants

10 objected, the parties met and conferred, and could not reach an agreement. ECF 11 No. 53 at 5. Defendants now seek a protective order. 12 LEGAL STANDARD

13 “[T]he scope of discovery is . . . any nonprivileged matter that is relevant to 14 any party’s claim or defense and proportional to the needs of the case . . . .” Fed. 15 R. Civ. P. 26(b)(1). Relevancy is “construed broadly to encompass any matter that

16 bears on, or that reasonably could lead to other matter that could bear on, any issue 17 that is or may be in the case.” Oppenheimer Fund, Inc. v. Sanders, 437 U.S. 340, 18 351 (1978). 19 Fed. R. Civ. P. 26(c) provides that “[a] party or any person from whom

20 discovery is sought may move for a protective order in the court where the action 1 is pending . . . . The court may, for good cause, issue an order to protect a party or 2 person from annoyance, embarrassment, oppression, or undue burden or expense . .

3 . .” “Rule 26(c) confers broad discretion on the trial court to decide when a 4 protective order is appropriate and what degree of protection is required.” Seattle 5 Times Co. v. Rhinehart, 467 U.S. 20, 36 (1984).

6 DISCUSSION 7 Defendants seek a protective order from discovery into: (1) their 8 employment policies from 2010 to 2018; (2) guidance, instruction, and directives 9 related to after Plaintiff’s 2013 reinstatement; (3) actions taken related to alleged

10 harassers following Plaintiff’s 2013 reinstatement; (4) any investigation into 11 Plaintiff’s 2013 reinstatement. ECF No. 53 at 4-5; ECF Nos. 54-7, 54-8. 12 Defendants argue that all issues related to pre-2018 conduct has been

13 decided in state court, thereby “prohibit[ing] Plaintiff from conducting this 14 discovery.” ECF No. 53 at 6. In essence, Defendants argue the discovery sought 15 is irrelevant. Defendants further argue that the requests are overbroad,

16 argumentative, and unduly burdensome. 17 A. Whether the Discovery is Relevant 18 The doctrines of “claim preclusion,” “issue preclusion,” “collateral 19 estoppel,” and/or “res judicata” prevent parties from re-litigating issues decided by

20 a prior court. See Migra v. Warren City School Dist. Bd. of Ed., 465 U.S. 75, 77 1 n.1 (1984); Rains v. State, 674 P.2d 165, 169 (Wash. 1983). These doctrines are 2 substantive defenses, most often argued in motions to dismiss or for summary

3 judgment. See, e.g., Ruiz v. Snohomish Cnty. Pub. Util. Dist. No. 1, 824 F.3d 1161, 4 1164-68 (9th Cir. 2016); Valley View Health Care, Inc. v. Chapman, 992 F. Supp. 5 2d 1016, 1044-48 (E.D. Cal. 2014); Seattle-First Nat’l Bank v. Kawachi, 588 P.2d

6 725, 726 (Wash. 1978). Here, Defendants argue that Plaintiff had claims relating 7 to pre-2018 conduct decided in state court, therefore this Court cannot allow 8 discovery into pre-2018 conduct. 9 The doctrines cited are substantive legal principles used to determine if relief

10 is available as a matter of law. Defendants offer no case law demonstrating their 11 use as a boundary to discovery. To the contrary, the scope of discovery is defined 12 primarily by relevance, proportionality, and burden. Fed. R. Civ. P. 26(b)(1). The

13 relevance of the discovery sought, here, is not diminished by the fact that Plaintiff 14 previously pursued claims from the same conduct. As Plaintiff highlights in 15 opposition, her claims allege harassment and retaliation arising in the wake of the

16 March 2018 trial. ECF No. 59 at 4-11. It is logical that actions and circumstances 17 from before March 2018 would be relevant to harassment and retaliation following 18 March 2018, at minimum as evidence of means, motive, and state of mind. 19 As to burden and proportionality, Defendants do not argue a particular

20 hardship from answering the discovery requests. Defendants only vaguely offer 1 that they “should not be forced to search for thirteen years of information on events 2 that have been fully litigated and adjudicated, as it would be costly, unduly

3 burdensome and not calculated to discover relevant information.” ECF No. 60 at 4 9-10. Defendants have offered no indication of the cost of such a search, the time 5 and manpower it would take, or what other hardships would be imposed.

6 The Court declines to grant a protective order on the basis that the 7 information sought is irrelevant due to res judicata or collateral estoppel. 8 B. Whether the Discovery is Argumentative, Overbroad, and Unduly Burdensome 9 Defendants argue that some of Plaintiff’s discovery requests are 10 argumentative, overbroad, and seek irrelevant information. ECF No. 53 at 10-13. 11 Many of Defendants’ arguments are vague. See ECF No. 53 at 11 (arguing that 12 “Plaintiff’s 30(b)(6) topics are overbroad,” while only providing two general 13 examples). The Court addresses only the arguments specifically stated. 14 Defendants argue that certain of the Fed. R. Civ. P. 30(b)(6) topics and 15 written discovery requests are argumentative and producing a deponent would 16 amount to an admission. ECF No. 53 at 10. The Court agrees that some of the 17 language used evokes a particular response or inference. Fed. R. Civ. P. 30

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Related

Oppenheimer Fund, Inc. v. Sanders
437 U.S. 340 (Supreme Court, 1978)
Seattle Times Co. v. Rhinehart
467 U.S. 20 (Supreme Court, 1984)
Rains v. State
674 P.2d 165 (Washington Supreme Court, 1983)
Simpson v. SISTERS OF CHARITY OF PROVIDENCE, ETC.
588 P.2d 4 (Oregon Supreme Court, 1978)
Caudle v. Thomason
992 F. Supp. 1 (District of Columbia, 1997)
ChriMar Systems Inc. v. Cisco Systems Inc.
312 F.R.D. 560 (N.D. California, 2016)

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Bluebook (online)
Tyler v. Chelan County, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tyler-v-chelan-county-waed-2023.