Meyer v. County of San Diego
3:21-cv-00341
S.D. Cal.Mar 11, 2025Background
- Plaintiffs alleged that San Diego County social workers violated their civil rights via improper video surveillance and false reporting during juvenile medical treatment.
- The Monell claims against the County were dismissed, leaving claims only against individual defendants Valenzuela, Craft, Paugh, and Snyder.
- Plaintiff Meyer filed a motion to compel certain discovery responses, specifically seeking social worker training materials withheld by defendants on privilege grounds.
- The at-issue training materials were created and provided by County attorneys, and most were presented after the key events forming the basis of the suit.
- Defendants voluntarily agreed to produce some materials but protected others, including those presented after the alleged violations, on the basis of attorney-client and work-product privileges.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Relevance of post-violation trainings | Trainings show what rights were clearly established, relevant to qualified immunity | Post-violation trainings are irrelevant & there's no Monell claim | Trainings after events not relevant; denied as to those |
| Privilege and work product | Primary purpose was training, not legal advice; privilege/work-product doesn’t apply | Trainings are legal advice to avoid litigation; privilege applies | Declaration supports privilege/work product on pre-incident training |
| Waiver of privilege | Objections waived by prior disclosures, implication, untimeliness | No waiver as County disclosures irrelevant and objections excusable | No waiver; good cause for timing |
| In camera review | Court should review withheld documents | No review needed; declaration sufficient | In camera review not needed |
Key Cases Cited
- Anderson v. Creighton, 483 U.S. 635 (objective qualified immunity standard)
- Hope v. Pelzer, 536 U.S. 730 (clearly established rights for qualified immunity)
- Pearson v. Callahan, 555 U.S. 223 (qualified immunity analysis framework)
- Hallett v. Morgan, 296 F.3d 732 (broad discretion for relevancy in discovery)
- United States v. Munoz, 233 F.3d 1117 (party asserting privilege bears burden)
- United States v. Richey, 632 F.3d 559 (attorney-client and work product standards)
- United States v. Ruehle, 583 F.3d 600 (attorney-client privilege requirements)
- Ballentine v. Tucker, 28 F.4th 54 (qualified immunity standards)
- Johnson v. Bay Area Rapid Transit Dist., 724 F.3d 1159 (qualified immunity does not bar state law claims)