Quinn v. Austin
1:24-cv-10285
D. Mass.Nov 13, 2023Background
- Quinn sued; Defendant Lloyd J. Austin III moved to stay discovery pending a forthcoming motion to dismiss.
- Defendant's motion contends the motion to dismiss will raise subject-matter jurisdiction and venue challenges that could dispose of or transfer the case.
- Quinn declined to stipulate to an extension but did not oppose the stay; the court treated Quinn’s failure to respond as an admission under the Local Rules.
- The court applied the two-part good-cause test for staying discovery pending a potentially dispositive motion (motion must be potentially dispositive and capable of resolution without further discovery).
- The court granted the stay, directed Defendant to file the motion to dismiss by November 14, 2023, and reset initial scheduling deadlines (Fed. R. Civ. P. 26(f) conference by 3/1/2024; initial disclosures by 3/18/2024; joint status report by 3/22/2024).
- Any further deadline extensions require court order; parties must meet and confer before seeking extensions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether to stay discovery pending a motion to dismiss | Quinn did not oppose the stay (though declined to stipulate) | Stay warranted because the motion challenges jurisdiction and venue and may dispose or transfer the case | Stay granted; good cause found |
| Whether the motion is potentially dispositive (jurisdiction/venue) | No contest (no opposition) | Subject-matter jurisdiction could dispose of case; venue challenge could transfer it | Court found potential to dispose or transfer, satisfying prong one |
| Whether the motion can be decided without additional discovery | No contest | Motion can be resolved on the complaint and EEO materials judicially noticeable | Court found no additional discovery required, satisfying prong two |
| Adjustment of scheduling deadlines and filing timeline | Declined to stipulate to extension | Requested stay and new deadlines; expected to file motion by Nov 14, 2023 | Court ordered new deadlines and directed motion to be filed by Nov 14, 2023 |
Key Cases Cited
- Jarvis v. Regan, 833 F.2d 149 (9th Cir. 1987) (district courts have broad discretion to stay discovery upon a showing of good cause)
- Little v. City of Seattle, 863 F.2d 681 (9th Cir. 1988) (recognizes district court discretion regarding stays pending dispositive motions)
- Panola Land Buyer’s Ass’n v. Shuman, 762 F.2d 1550 (11th Cir. 1985) (articulates two-part test for staying discovery pending a dispositive motion)
- Twin City Fire Ins. Co. v. Emps. Ins. of Wausau, 124 F.R.D. 652 (D. Nev. 1989) (challenge to venue is a common example warranting a discovery stay)