DAVIS v. MARION COUNTY SUPERIOR COURT JUVENILE DETENTION CENTER, 1:24-cv-01918

Yvonne L. Davis, former Director of Staff and Youth Services at the Marion County Superior Court Juvenile Detention Center (JDC), was terminated after reporting a coworker's concerns about two administrators.
Davis previously filed “Davis I” alleging her termination was retaliatory; the federal claims were resolved in favor of the defendants and the court relinquished state claims.
While Davis I was pending, Davis reapplied for her old position in July 2023 and was not rehired, leading to the present lawsuit alleging retaliatory refusal to rehire and gender discrimination.
Defendants sought further discovery regarding Davis’s post-termination employment efforts and tax records, arguing this information was relevant to her claims and damages.
Plaintiff resisted by objecting to the relevance, scope, and privacy implications, also invoking privilege over certain interrogatories.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of discovery/timeframe	Discovery for events between 2022 termination and 2023 reapplication is irrelevant and seeks a "do-over" of Davis I discovery.	Events post-termination through application period are relevant to current claims.	Discovery is allowed; prior suit's closure irrelevant.
Privilege over communications	Communications with family members are privileged/private.	Plaintiff did not properly invoke privilege; only identification is sought.	Privilege arguments waived; identification must be disclosed.
Production of tax returns	Tax returns (esp. for 2023-24) are irrelevant, overbroad, as Plaintiff was unemployed and wage info is available by other means.	Tax returns are relevant to damages; no heightened standard for relevance applies in 7th Circuit.	Tax returns are discoverable if relevant/proportional.
Adequacy of prior responses	Plaintiff claims responses are already full within scope of current litigation.	Defendants believe prior responses are incomplete, especially as to timeframe.	Plaintiff must certify responses are complete and not time-limited.

Poulos v. Naas Foods, Inc., 959 F.2d 69 (7th Cir. 1992) (Seventh Circuit does not require heightened showing for discovery of tax returns; standard relevance/proportionality test under Rule 26)
Schaefer v. Universal Scaffolding & Equip., LLC, 839 F.3d 599 (7th Cir. 2016) (perfunctory and undeveloped arguments, and those unsupported by legal authority, are waived)
Draper v. Martin, 664 F.3d 1110 (7th Cir. 2011) (court is not responsible for developing parties’ legal arguments)
Novelty, Inc. v. Mountain View Mktg., 265 F.R.D. 370 (S.D. Ind. 2009) (generalized objections without specificity are insufficient to preserve a privilege)