Boyd v. Youth Opportunity Investments, LLC (TV1), 3:20-cv-00321

Plaintiff (Boyd) alleges state-law wrongful termination/retaliation and related statutory claims after reporting suspected staff sexual misconduct and other regulatory violations at a youth residential facility.
Plaintiff served a subpoena duces tecum on opposing counsel (Employment and Consumer Law Group), seeking electronic copies of all depositions of Youth Opportunity Investments managers/employees from a similar earlier case, Llana v. Youth Opportunity Investments, LLC.
Defendant moved to quash the subpoena, arguing lack of relevance and that the Llana transcripts/exhibits contain confidential information protected by Tennessee statutes governing child-abuse, juvenile, and mental-health records.
The court found Defendant has standing to object because it asserted a personal/proprietary interest in preventing disclosure of confidential juvenile information.
The court held the Llana depositions were relevant and proportional but recognized a substantial state-law confidentiality concern; because the court could not determine from the subpoena whether protected material was included, it granted the motion to quash while ordering the parties to meet-and-confer and directing Defendant to produce any non-protected deposition material after Plaintiff specifies the testimony sought.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to quash subpoena to nonparty counsel	Defendant has personal interest because requested materials concern Defendant and its managers	No standing ordinarily to quash subpoenas to nonparties absent personal right/privilege	Court: Defendant has standing because it asserted a personal/proprietary interest
Relevance of Llana depositions	Testimony from the same corporate managers about investigative practices is relevant and proportional	Testimony from a different facility and different time is not relevant	Court: Depositions are relevant and proportional under Rule 26(b)(1)
State-law confidentiality vs. federal discovery	Plaintiff seeks corporate practice testimony, not DCS records; any protected material can be redacted	Deposition transcripts/exhibits likely contain records/identities protected by Tennessee statutes; disclosure could be unlawful/criminal	Court: State confidentiality statutes may bar disclosure; cannot determine without review; state interests weigh heavily in diversity/state-law case
Remedy	Compel production of Llana depositions	Quash subpoena or limit disclosure of protected material	Court: Grants motion to quash, but orders meet-and-confer; Defendant to produce non-protected testimony after Plaintiff narrows requests

Meredith v. United Collection Bureau, Inc., 319 F.R.D. 240 (N.D. Ohio 2017) (discovery scope under Rule 26 is broad but subject to proportionality)
Lewis v. ACB Bus. Servs., Inc., 135 F.3d 389 (6th Cir. 1998) (federal discovery scope traditionally broad)
Surles v. Greyhound Lines, Inc., 474 F.3d 288 (6th Cir. 2007) (trial court retains discretion to limit or deny overly broad discovery)
Farley v. Farley, 952 F. Supp. 1232 (M.D. Tenn. 1997) (state confidentiality may yield in federal civil-rights cases, but less so in ordinary state-law actions)