Labrier v. State Farm Fire & Casualty Co., 2016 U.S. Dist. LEXIS 61246

Background

Plaintiff Amanda LaBrier seeks class-wide discovery about State Farm’s withholding of labor depreciation from ACV payments and related dates/amounts; State Farm removed the case and used insurer/Xactware data in its initial submissions.
LaBrier served repeated discovery (requests, interrogatories, depositions, subpoenas) seeking lists of data fields and remote access to State Farm’s claim system and Xactware databases; State Farm refused, citing confidentiality and trade secrets.
Depositions of State Farm and Xactware engineers established that lists of data fields exist and that data can be exported to spreadsheets; State Farm nonetheless resisted producing the fields or system access.
Special Master Shurin held multiple hearings, concluded the interrogatories were relevant and proportional under Rule 26, and ordered State Farm to answer interrogatories identifying, for each covered claim, the labor depreciation withheld, dates of withholding, any subsequent payments of withheld amounts, and applicable affirmative defenses.
State Farm moved to vacate or suspend the Special Master’s order arguing undue burden and disproportionate discovery; the district court reviewed for abuse of discretion.
The court denied State Farm’s motion, finding State Farm failed to show an undue burden or lack of proportionality, and assigned to State Farm the cost of extracting responsive information it controls.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Special Master abused discretion ordering State Farm to answer interrogatories about labor depreciation and related dates/amounts	Interrogatories seek relevant, proportional class-member and damages data; plaintiff lacks independent access	Compliance is unduly burdensome, requires complex, claim-by-claim queries across proprietary systems; trade-secret concerns justify refusal	No abuse of discretion; interrogatories are within Rule 26 scope and proportional — order affirmed
Whether district court should apply de novo review to Special Master’s discovery order	(implicitly) Special Master’s procedural rulings should be reviewed deferentially	Argued for de novo review by analogy to report-and-recommendation cases	Court applies abuse-of-discretion standard because Special Master was authorized to make discovery orders
Whether State Farm’s claimed recordkeeping deficiencies excuse production	Plaintiff: insurer’s inability to produce lists does not justify withholding discovery; State Farm controls data	State Farm: inability to export data without significant programming and expense makes discovery disproportionate	Court: State Farm must bear cost; refusal to allow access or provide fields created burden, so objections insufficient
Whether individualized claim review defeats discovery/class-certification discovery need	Plaintiff: many responsive data points can be derived from computerized records without individualized file review; class discovery remains appropriate	State Farm: individualized review is required, making class discovery disproportionate	Court: Special Master reasonably concluded much data can be obtained electronically; burden not undue and discovery proportional

Key Cases Cited

Admiral Theatre Corp. v. Douglas Theatre Co., 585 F.2d 877 (8th Cir.) (district court discretion in discovery scope)
Villar v. Crowley Maritime Corp., 990 F.2d 1489 (5th Cir.) (broad discovery on class-certification issues)
Kamm v. California City Dev. Co., 509 F.2d 205 (9th Cir.) (discretion on discovery for class issues)
Johnson v. Nekoosa-Edwards Paper Co., 558 F.2d 841 (8th Cir.) (broad discovery normally permitted prior to class certification)
Rubin v. Islamic Republic of Iran, 349 F. Supp. 2d 1108 (N.D. Ill.) (burden on objecting party to justify limiting discovery)
St. Paul Reinsurance Co. v. Commercial Fin. Corp., 198 F.R.D. 508 (N.D. Iowa) (bare assertions of burden ordinarily insufficient to bar production)