Haughton v. District of Columbia
161 F. Supp. 3d 100
| D.D.C. | 2014Background
- Plaintiff Phillip Haughton moved to compel supplemental discovery after Defendant responded to interrogatories and document requests by referring to produced documents rather than giving specific answers.
- Magistrate Judge Alan Kay granted the motion in part (July 15, 2014), ordering Defendant to either provide specific answers or designate narrow page ranges and to resubmit a proper response to one request for admission.
- Plaintiff objected, seeking a ruling that documents should not be used to answer interrogatories and asking for more specific responses plus a 60-day extension.
- Defendant also sought to stay compliance and filed objections to the Magistrate Judge’s order; the district court denied the initial stay and later addressed both parties’ objections.
- The district court reviewed the Magistrate Judge’s nondispositive ruling under the clearly erroneous or contrary to law standard and affirmed it, directing Defendant to comply by an amended deadline and setting a new discovery cutoff.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether referring to produced documents satisfies interrogatory responses under Rule 33(d) | Haughton: Defendant should not answer by producing documents; needs specific answers | Defendant: Proper to rely on Rule 33(d) and refer to documents instead of specific answers | Court: Referring to documents can be proper, but if done, defendant must specify records or narrow page ranges so answers are as accessible as to responding party |
| Adequacy of directing plaintiff to large/unindexed document production | Haughton: Directing to hundreds/thousands of pages without index is inadequate and unduly burdensome | Defendant: Burden of deriving answers is similar; broad referral is acceptable | Court: Magistrate not clearly erroneous; ordered defendant to supply narrow page ranges or specific answers because mass referrals are insufficient |
| Defendant’s response to a request for admission | (No objection) Haughton sought a proper admission/denial | Defendant initially denied without good-faith basis | Court: Magistrate required defendant to resubmit a proper response; no party objects to that portion and it stands |
| Standard of review for Magistrate Judge’s discovery rulings and stay request | Haughton: Magistrate’s order should be enforced; requested extension to review supplements | Defendant: Asked district court to stay compliance and later sought reconsideration of denial of stay | Court: Applied "clearly erroneous or contrary to law" standard; affirmed Magistrate’s order, denied the stay, granted reconsideration narrowly but denied stay relief, and set compliance/deadlines |
Key Cases Cited
- United States v. U.S. Gypsum Co., 338 U.S. 364 (standard for "clearly erroneous" review)
- Food Lion, Inc. v. United Food & Commercial Workers Int’l Union, 103 F.3d 1007 (district courts have broad discretion in discovery)
- Neuder v. Battelle Pac. Nw. Nat’l Lab., 194 F.R.D. 289 (deference to magistrate judges on discovery rulings)
- United States v. Kellogg Brown & Root Servs., 284 F.R.D. 22 (Rule 33(d) requires specification of records so interrogating party can locate information)
- Cambridge Elec. Corp. v. MGA Elecs., Inc., 227 F.R.D. 313 (Rule 33(d) requires direction to where information will be found)
- Graske v. Auto-Owners Ins. Co., 647 F. Supp. 2d 1105 (responding party cannot simply direct to a mass of records)