Latoya Lawson v. City of Jackson, Mississippi, 349 So.3d 724

On March 9, 2018 Latoya Lawson was injured after hitting a pothole while riding a motorcycle in Jackson, Mississippi; she sued the City on March 29, 2019 alleging negligent road maintenance.
The parties worked under a scheduling order with discovery originally due November 29, 2019; later parties discussed extending the deadline to November 15, 2020, but no amended order was entered.
Lawson served written discovery and a public-records request in early November 2020, shortly before the November 15, 2020 discovery cutoff.
The City moved for a protective order, arguing Lawson was dilatory and that her requests would force responses after the discovery deadline and that a public-records request sought to circumvent discovery rules.
The trial court barred the City from having to respond to Lawson’s late production requests, prohibited Lawson from making public-records requests to the City, and barred her from using any public records obtained against the City; Lawson obtained interlocutory review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether protective order barring City's response to Lawson's late request for production was proper	Lawson contended protective order was an abuse of discretion	City argued Lawson was dilatory and responses would be due after the discovery cutoff, causing prejudice	Affirmed — trial court acted within its Rule 26(d) discretion; Lawson delayed discovery and would prejudice City
Whether trial court could bar Lawson from making public-records requests to the City	Lawson argued she has a statutory right under the Mississippi Public Records Act to request records	City argued public-records request was a device to bypass discovery deadlines and thus could be restricted	Reversed — statutory right to access public records cannot be prohibited by discovery protective order absent statutory exception
Whether trial court could preclude use at trial of any public records Lawson obtains	Lawson argued public records are admissible under evidence rules and her request is not discovery abuse	City argued sanctioning exclusion was appropriate as remedy for circumvention of discovery	Reversed — court abused discretion; use/admissibility governed by Rules of Evidence, not by blanket discovery sanction; Lawson must still supplement discovery responses if she obtains new records

Ashmore v. Miss. Auth. on Educ. Television, 148 So. 3d 977 (Miss. 2014) (trial courts afforded broad discretion in discovery matters)
Pierce v. Heritage Props., Inc., 688 So. 2d 1385 (Miss. 1997) (discussing appellate review of discovery rulings)
City of Jackson v. Rhaly, 95 So. 3d 602 (Miss. 2012) (standard for affirming exercise of correct legal standard in discovery)
Blossom v. Blossom, 66 So. 3d 124 (Miss. 2011) (interlocutory appeals in discovery matters scrutinized strictly)
Pat Harrison Waterway Dist. v. Cnty. of Lamar, 185 So. 3d 935 (Miss. 2016) (statutory-interpretation principle: do not interpret plain unambiguous statutes)
Knapp v. St. Dominic-Jackson Mem’l Hosp., 89 So. 3d 561 (Miss. 2012) (continuing duty to supplement discovery responses)