Wayne K. Smith, Sr., Individually and as Personal Representative of the Estate of Wayne K. Smith, Jr., deceased v. Polk County, et al.

CourtDistrict Court, W.D. North Carolina
DecidedJune 2, 2026
Docket1:24-cv-00037
StatusUnknown

This text of Wayne K. Smith, Sr., Individually and as Personal Representative of the Estate of Wayne K. Smith, Jr., deceased v. Polk County, et al. (Wayne K. Smith, Sr., Individually and as Personal Representative of the Estate of Wayne K. Smith, Jr., deceased v. Polk County, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Wayne K. Smith, Sr., Individually and as Personal Representative of the Estate of Wayne K. Smith, Jr., deceased v. Polk County, et al., (W.D.N.C. 2026).

Opinion

THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION CIVIL CASE NO. 1:24-cv-00037-MR-WCM

WAYNE K. SMITH, SR., Individually ) and as Personal Representative of ) the Estate of Wayne K. Smith, Jr., ) deceased, ) ) Plaintiff, ) ) vs. ) MEMORANDUM OF ) DECISION AND ORDER POLK COUNTY, et al., ) ) Defendants. ) ________________________________ )

THIS MATTER is before the Court on the Plaintiff’s Motion to Compel Non-Party North Carolina State Highway Patrol to Comply with Subpoena and for Fees [Doc. 46] and Motion to Compel Defendant to Answer Plaintiff’s Second Set of Interrogatories and for Fees [Doc. 57]. I. BACKGROUND This action arises from the circumstances of the Decedent Wayne K. Smith, Jr.’s death. On February 2, 2021, Defendant Deputy Ben Page noticed the Decedent speeding, activated his blue lights, and pursued the Decedent. [Doc. 4 at ¶¶ 36-40]. The vehicles exceeded 75 miles per hour in a 45 mile-per-hour zone, and, as the vehicles neared a curve in the road, the Decedent’s vehicle “spun out of control and collided into a tree.” [Id. at ¶¶ 38, 42-45]. The collision caused the Decedent’s death. [Id. at ¶ 50].

On February 2, 2024, the Plaintiff Wayne K. Smith, Sr., individually and as the personal representative of the Decedent, initiated this action asserting various constitutional violations pursuant to 42 U.S.C. § 1983, violation of 42

U.S.C. § 1981, and claims for wrongful death, battery, false imprisonment, intentional infliction of emotional distress, negligent infliction of emotional distress, and punitive damages. [Doc. 1]. On April 7, 2025, the Court dismissed all of the Plaintiff’s claims except for a § 1983 deliberate

indifference claim stemming from Defendant Page’s alleged actions after the Decedent crashed into a tree, and the Plaintiff’s corresponding claim for punitive damages. [Doc. 14].

The Plaintiff has now filed two motions to compel that are currently pending: one against non-party North Carolina State Highway Patrol (“NCSHP”), and another against Defendant Page. [Docs. 46, 57]. Having been fully briefed,1 both motions are ripe for disposition.

1 The Plaintiff did not file a Reply in support of the motion to compel NCSHP, but the time period within which to do so expired on May 18, 2026. II. STANDARD OF REVIEW Rule 26 of the Federal Rules of Civil Procedure provides, in pertinent

part, as follows: Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties’ relative access to relevant information, the parties’ resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

Fed. R. Civ. P. 26(b)(1). Under Rule 37 of the Federal Rules of Civil Procedure, “a party may move for an order compelling disclosure or discovery.” Fed. R. Civ. P. 37(a)(1). “[T]he party or person resisting discovery, not the party moving to compel discovery, bears the burden of persuasion.” Kinetic Concepts, Inc. v. ConvaTec Inc., 268 F.R.D. 226, 243 (M.D.N.C. 2010). The decision to grant or deny a motion to compel is generally an issue within the broad discretion of the trial court. See Lone Star Steakhouse & Saloon, Inc. v. Alpha of Va., Inc., 43 F.3d 922, 929 (4th Cir. 1995). III. DISCUSSION A. Motion to Compel the North Carolina State Highway Patrol

On April 11, 2026, the Plaintiff moved to compel non-party NCSHP to comply with a Rule 45 subpoena that requested records of Defendant Page’s vehicle accident history across a period of sixteen years, records of any

instances of NCSHP’s interactions with Defendant Page, and records of two vehicle collisions in 2020 in which Defendant Page was involved. [Doc. 46 at 1-2]. The Plaintiff contends that Defendant Page’s “driving history, disciplinary record, and prior conduct in similar situations are directly relevant

to the surviving [deliberate indifference] claim and [Defendant Page’s] credibility.” [Doc. 46-1 at 3]. The Court notes, however, that the relevance of such discovery to the deliberate indifference claim is, at best, tenuous.

Exhibits filed with the Plaintiff’s motion and NCSHP’s response reveal that the parties were engaged in productive communications regarding the subpoena until the Plaintiff filed the motion to compel, and that NCSHP has diligently attempted to comply with the subpoena. On April 6, 2026, NCSHP

informed the Plaintiff’s counsel via email that, pursuant to a routine retention schedule, NCSHP no longer possessed the requested records of the two 2020 collisions. [Doc. 46-4 at 2]. In that same email, NCSHP also offered

to search certain email inboxes with particular parameters in order to comply with the subpoena. [Id.]. Counsel for the Plaintiff appears not to have replied to NCSHP until five days later, at 12:27pm on Saturday, April 11, 2026, at

which time counsel for the Plaintiff posed several questions to NCSHP. [Id. at 1]. Then, instead of waiting for a response from NCSHP, the Plaintiff filed a motion to compel NCSHP later that evening. [Doc. 46; Doc. 62-9 at 1]. In

the memorandum in support of that motion, the Plaintiff represents that the Plaintiff accepted NCSHP’s April 6, 2026 offer to conduct an email inbox search for records and then states that “[a]n agreement to search is meaningless without production of results.” [Doc. 46-1 at 20]. At the time of

filing that statement, however, the Plaintiff appears to have given NCSHP only seven hours on a Saturday afternoon to produce the results in question. Moreover, there is no indication that counsel for the Plaintiff attempted to

consult with NCSHP regarding the motion to compel as required by Local Rule 7.1(b) before filing the motion. See LCvR 7.1(b). Additionally, since the filing of the motion to compel, NCSHP appears to have continued to attempt to comply with the subpoena. See [Doc. 62-11]; see also [Doc. 87 at 5].

Accordingly, the Court concludes that the Plaintiff’s motion to compel NCSHP was filed prematurely, unnecessarily, and without the consultation required by the Local Rules. The Court will therefore deny the Plaintiff’s

motion to compel NCSHP. B. Motion to Compel Defendant Page

On April 30, 2026, the Plaintiff moved to compel Defendant Page “to substantively respond to Plaintiff’s second set of interrogatories.”2 [Doc. 57 at 1]. Specifically, the Plaintiff has requested that Defendant Page provide information regarding an incident in July 2017 when Defendant Page

allegedly pointed a loaded gun at a television, as well as information regarding Defendant Page’s separation from employment as a part-time deputy with the Polk County Sheriff’s Office in February 2013. [Doc. 57-2 at 4].

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Wayne K. Smith, Sr., Individually and as Personal Representative of the Estate of Wayne K. Smith, Jr., deceased v. Polk County, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/wayne-k-smith-sr-individually-and-as-personal-representative-of-the-ncwd-2026.