Chennareddy v. Walker
282 F.R.D. 9
D.D.C.2012Background
- This is a District of Columbia civil action by Chennareddy and other GAO employees against Acting Comptroller General Dodaro alleging age-based discrimination under the ADEA.
- The case has a long history, including multiple amendments and an unsuccessful attempt to certify a class under Rule 23.
- The court previously held that the plaintiffs lacked commonality/typicality and failed to show a common discriminatory practice; class certification was denied in 1995 and reaffirmed in 1999.
- After reassignment in 2007, plaintiffs filed a fourth amended complaint and sought discovery related to GAO’s electronic databases, which the court repeatedly denied.
- Defendant moved for a more definite statement or dismissal based on Rule 8/Rule 10 deficiencies; the court required a sixth amended complaint with specific facts for each plaintiff.
- The court ultimately struck the sixth amended complaint and dismissed the action with prejudice for noncompliance, and denied reconsideration of discovery denials.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the sixth amended complaint should be struck and the action dismissed | Chennareddy argues discovery and exhibits should satisfy Rule 8; seeks relief | Complaint remains incoherent, overbroad, and fails to comply with Rule 8/12(e) despite orders | Yes; the court dismissed the action with prejudice under Rule 12(e) and Rule 8. |
| Whether the court should reconsider discovery denials | Requests for discovery of electronic GAO database should be reconsidered | Discovery denials should stand to preserve pleading requirements | No; cross-motion denied; discovery denials affirmed. |
| Whether dismissal is proper under Rule 41(b) as a sanction for noncompliance | Plaintiffs contend they complied with orders and should proceed | Persistent noncompliance with court orders warrants dismissal | Court relied on Rule 12(e) and 8(d) and dismissed with prejudice. |
Key Cases Cited
- Shallal v. Gates, 254 F.R.D. 140 (D.D.C. 2008) (striking complaint for failure to comply with 12(e) and 8; heavy sanctions justified when repeated noncompliance)
- Salahuddin v. Cuomo, 861 F.2d 40 (2d Cir. 1988) (pleading must be short, plain, and understandable; avoid prolixity)
- Ciralsky v. CIA, 355 F.3d 661 (D.C. Cir. 2004) (Rule 8; pleadings must provide fair notice and be concise; exhibits should not overwhelm pleadings)
- McHenry v. Renne, 84 F.3d 1172 (9th Cir. 1996) (affirming dismissal for purposeful failure to file a concise complaint under Rule 8)
- Firestone v. Firestone, 76 F.3d 1205 (D.C. Cir. 1996) (standard for reconsideration and timely corrections to interlocutory rulings)