Mannon v. VAMC Ann Arbor
2:23-cv-12612
E.D. Mich.Mar 11, 2025Background
- Plaintiff Steven Roger Mannon filed suit under the Privacy Act, seeking review of the Department of Veterans Affairs' denial of his request to amend a VA medical record he claims is inaccurate.
- Mannon alleges his medical record wrongly characterizes him as aggressive and noncompliant during a particular appointment.
- The case was referred to Magistrate Judge Elizabeth A. Stafford for pretrial proceedings.
- Mannon filed a motion to compel the government to produce additional documents, aiming to supplement the administrative record.
- The government opposed, arguing that Mannon had not properly requested discovery and that his document requests were overbroad and insufficiently specific.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mannon's motion to compel should be granted | Sought production of all records he deemed pertinent to his claim | Mannon failed to make valid discovery requests and requests were overbroad | Motion to compel denied |
| Sufficiency and specificity of document requests | Requested various broad categories of documents with vague descriptions | Requests were overly broad, vague, and not limited to relevant timeframe | Requests did not comply with discovery rules |
| Relevance of requested documents | Implied documents would support his contention of record inaccuracies | Mannon did not explain how the documents were relevant to his specific claim | Relevance not demonstrated; motion denied |
| Compliance with federal discovery procedures | Sought court order for production without formal discovery request | No discovery request served as required by federal rules | Motion denied for failure to follow procedure |
Key Cases Cited
- Cheney v. U.S. Dist. Court for D.C., 542 U.S. 367 (2004) (document requests asking for everything under the sky are inappropriate)
- Helena Agri-Enterprises, LLC v. Great Lakes Grain, LLC, 988 F.3d 260 (6th Cir. 2021) (parties and courts must consider proportionality in discovery)
- Transamerica Life Ins. Co. v. Moore, 274 F.R.D. 602 (E.D. Ky. 2011) (overly broad or unduly burdensome discovery requests are improper)