DeLeon-Reyes v. Guevara, 1:18-cv-01028

These are two related civil rights cases (Reyes and Solache) involving Monell discovery directed at two Cook County offices: the Public Defender (CCPD) and the State’s Attorney (CCSAO).
Plaintiffs served a subpoena on the CCPD and obtained partial production; the City (defendant) later served a subpoena on the CCSAO for related files.
The Court previously limited production to roughly 100 files from each third party and shifted production burden away from the third parties; CCPD has completed production and CCSAO production is ongoing.
The City moved for a protective order to halt further Monell discovery and stop third-party productions; the Court treated that motion as a motion for reconsideration of prior discovery orders.
The parties dispute whether certain polaroid photographs in CPD files (alleged Brady material) were suppressed in the criminal case; Plaintiffs contend these support continued Monell discovery, while the City argues they are not Brady or are irrelevant.
The magistrate judge denied the City’s motion, finding it procedurally improper, largely moot, lacking standing on burden grounds, and premature as to merits issues like Brady.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the City’s motion was procedurally proper or a motion for reconsideration	Plaintiffs relied on prior production orders and oppose further delay	City re-urged burden/relevancy objections and sought to halt ordered productions	Motion treated as reconsideration and denied; no new basis shown to disturb prior rulings
Whether the motion is moot given current productions	Plaintiffs point out CCPD production complete and CCSAO ongoing; discovery should proceed	City sought to stop remaining CCSAO production	Court found motion largely moot because CCPD production finished and CCSAO work nearly complete
Whether the City has standing to seek protection from burden of third-party subpoenas	Plaintiffs: City lacks standing to quash nonparty subpoenas and third parties raised burden objections themselves	City: argues broad burden on public entities justifies protective relief	Court held City lacks standing to quash third-party subpoenas based on burden; protective relief not warranted on this record
Whether contested Brady issues justify halting Monell discovery	Plaintiffs: alleged missing/exculpatory photos justify Monell discovery to probe policies/practices	City: Brady dispute is dispositive and counsels stopping Monell discovery now	Court held Brady/merits disputes are for summary judgment/trial and do not justify shutting down Monell discovery now

Hicks v. Midwest Transit, Inc., 531 F.3d 467 (7th Cir. 2008) (motions for reconsideration limited to correcting manifest errors or newly discovered evidence)
S.E.C. v. Lipson, 46 F.Supp.2d 758 (N.D. Ill. 1998) (motions to reconsider are not for rehashing arguments previously rejected)
Caine v. Burge, 897 F.Supp.2d 714 (N.D. Ill. 2012) (movant bears a heavy burden on reconsideration)
Parker v. Four Seasons Hotels, Ltd., 291 F.R.D. 181 (N.D. Ill. 2013) (party generally lacks standing to quash subpoena directed to a nonparty)
United States v. Raineri, 670 F.2d 702 (7th Cir. 1982) (party may have standing to challenge a subpoena when it infringes legitimate interests)