Coleman v. American Family Mutual Insurance, 274 F.R.D. 641

Court-wide management order required Coleman to serve expert disclosures by December 29, 2010.
Coleman identified five experts on December 27, 2010: a vocational-rehabilitation specialist and four treating physicians.
Coleman provided a written report for the vocational-rehabilitation specialist but no written reports for the treating physicians.
American Family requested full expert reports for the four treating physicians; Coleman refused.
Defendant moved to compel disclosure of treating-physician reports; Court granted the motion.
Court analyzed Rule 26 amendments and the treating-physician disclosure requirements under Rule 26(a)(2)(B)-(C).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether treating physicians must file full expert reports	Coleman argues Meyers requires full reports for treating physicians who opine on causation.	American Family argues Rule 26 amendments allow only summary disclosures for non-retained physicians.	Treating physicians need not file full reports but must provide summary disclosures under 26(a)(2)(C).

Meyers v. National R.R. Passenger Corp., 619 F.3d 729 (7th Cir. 2010) (treating physicians testifying on causation may be required to file an expert report)
Musser v. Gentiva Health Services, 356 F.3d 751 (7th Cir. 2004) (distinguishes treating physicians from retained experts; scope of Rule 26(a)(2))
Banister v. Burton, 636 F.3d 828 (7th Cir. 2011) (distinguishes who must provide expert reports under Rule 26(a)(2))
Zarecki v. Nat’l R.R. Passenger Corp., 914 F. Supp. 1566 (N.D. Ill. 1996) (treating physician testimony limited to observations does not require Rule 26(a)(2) report)
Sanyo Laser Prods., Inc. v. Arista Records, Inc., 214 F.R.D. 496 (S.D. Ind. 2003) (discusses scope of relevance and discovery procedures in complex matters)
Berning v. UAW Local 2209, 242 F.R.D. 510 (N.D. Ind. 2007) (examines balancing of discovery value vs. burden under Rule 26)