RICE v. CITY OF PHILADELPHIA
2:24-cv-04882
E.D. Pa.May 19, 2025Background
- Plaintiff Charles Rice brought suit against the City of Philadelphia and others, alleging significant damages tied to deprivations of academic and professional opportunities stemming from events occurring when he was seventeen years old.
- Rice moved for a protective order to prevent discovery of his elementary school records, academic disciplinary records, and other unspecified school documents, citing privacy concerns and irrelevance.
- Rice also moved to compel the Defendants to produce documents showing specific areas of the police station where he was interrogated during a 2011 investigation, arguing relevance to his claims.
- Defendants argued for access to Rice's school records from all years to investigate his damages claims and opposed production of police station documents due to safety and burden concerns.
- The Court's decision addresses both discovery disputes, balancing privacy, relevance, and proportionality under Federal Rule of Civil Procedure 26.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Discovery of Elementary School & Academic Disciplinary Records | Disclosure invades privacy, records not relevant; high school records are sufficient | Need full academic record to respond to damages claims tied to alleged lost academic/professional opportunities | Defendants may discover Plaintiff's school records, including disciplinary records, only from fifth grade onward |
| Discovery of "Other Documents" in School File | Request is vague, overbroad, and invades privacy | Documents are relevant to academic/potentially professional trajectory claims | Defendants may obtain such documents, limited to files from fifth grade onward |
| Compelling Police Station Layout Documents | Documents are relevant to claims regarding interrogation and Plaintiff’s mobility limitations | Production creates undue safety risk, confidentiality concerns, and is burdensome | Motion to compel granted; documents to be produced with “Attorneys’ Eyes Only” protection, limited to areas where Plaintiff was questioned |
Key Cases Cited
- In re Avandia Mktg., Sales Practices & Prods. Liab. Litig., 924 F.3d 662 (3d Cir. 2019) (enumerates factors courts should consider when issuing protective orders concerning discovery)
- United States v. Miami Univ., 294 F.3d 797 (6th Cir. 2002) (applies FERPA to academic disciplinary records, affirming judicial disclosure protocols)
- Mervilus v. Union County, 73 F.4th 185 (3d Cir. 2023) (discusses relevance of evidence to fabrication claims and elements required for such claims)