Arnold v. ADT Security Services, Inc.
627 F.3d 716
| 8th Cir. | 2010Background
- Plaintiffs sued ADT for racial discrimination, hostile work environment, and negligent infliction of emotional distress (2005); Doran joined in 2006.
- Discovery remained incomplete two years later; district court set deadlines and authorized a motion to compel sanctions.
- Court ordered plaintiffs to complete discovery by Jan 30, 2009 and warned of dismissal for noncompliance.
- ADT moved to compel; district court granted motion, imposed sanctions ($100 per day) on most plaintiffs and Sullivant.
- Sullivant withdrew; Arnold, Braxton, and Doran were dismissed with prejudice for failing to attend status conferences; appeal followed.
- Court affirmed the district court’s order granting the motion to compel, sanctions, reconsideration denial, and dismissal with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether discovery sanctions and attorney’s fees were proper | Doran and Sullivant argue lack of good faith and unjust fees | ADT showed good-faith conferral and justified sanctions | Yes; sanctions and fees upheld |
| Whether reconsideration and stay were properly denied | ADT supplemental disclosures were newly discovered evidence | Disclosures were not newly discovered; due diligence lacking | No abuse of discretion; denial affirmed |
| Whether dismissal with prejudice was appropriate | Dismissal too harsh; less severe sanctions available | Pattern of delay and failure to comply warranted; dismissal appropriate | Yes; dismissal with prejudice affirmed for noncompliance |
| Due process concerns regarding notices for conferences | Some notices returned; due process violated | Notices satisfactorily delivered; adequate contact maintained | Not a reversible error; district court did not abuse discretion |
Key Cases Cited
- Chrysler Corp. v. Carey, 186 F.3d 1016 (8th Cir. 1999) (standard for discovery sanctions and attorney's fees awards)
- Arnold v. Wood, 238 F.3d 992 (8th Cir. 2001) ( Rule 60(b) reconsideration scope; abuse of discretion)
- Hunt v. City of Minneapolis, 203 F.3d 524 (8th Cir. 2000) (dismissal with prejudice as extreme sanction; factors for abuse of discretion)
- Hutchins v. A.G. Edwards & Sons, Inc., 116 F.3d 1256 (8th Cir. 1997) (would weigh burden on court against prejudice to other party)
- United States v. Metro. St. Louis Sewer Dist., 440 F.3d 930 (8th Cir. 2006) (fraud/misrepresentation standard for Rule 60(b)(3))
- Moore v. City of Des Moines, 766 F.2d 343 (8th Cir. 1985) (fee-shifting and reasonableness in sanctions context)
- Collins v. Burg, 169 F.3d 563 (8th Cir. 1999) (reasonableness of hours and rates in calculating sanctions)