Sheets v. Presseller
2:24-cv-00495
M.D. Fla.Mar 11, 2025Background
- Andrew Bryant Sheets, a pro se plaintiff, sued the City of Punta Gorda and others under the First Amendment, challenging his trespass from a local farmers market, alleging a right to conduct journalistic activities there.
- Sheets served broad discovery requests to the City, seeking all records mentioning either "Ian McGuire" (regarding filming activities) or himself from 2019 to the present.
- The City argued the discovery requests were overbroad and unduly burdensome under Rule 26 of the Federal Rules of Civil Procedure.
- Sheets' motion to compel discovery responses was briefed; the City also alleged Sheets used generative AI to draft filings and cited non-existent cases in correspondence.
- The case procedurally is at the pretrial discovery stage, addressing the appropriateness and scope of document production requests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of Discovery Requests | Requests are relevant to show "unconstitutional selective enforcement" | Requests are overbroad, unduly burdensome, and not proportional to the case | Requests are overbroad; motion to compel denied |
| Relevance of Ian McGuire Documents | Relevant to establish pattern of enforcement | No claim of selective enforcement alleged; not limited to farmers market, so irrelevant | Sheets failed to show relevance; discovery denied |
| Duty of Candor in Submissions | (not directly addressed) | Sheets' filings and correspondence relied on AI and non-existent case law | Plaintiff must verify legal sources; sanctions possible for future violations |
| City's Motion to Strike | (not addressed) | Clarification by Sheets unnecessary | Denied as moot |
Key Cases Cited
- Josendis v. Wall to Wall Residence Repairs, Inc., 662 F.3d 1292 (11th Cir. 2011) (requests for all documents relating to allegations are overbroad)
- Goodbys Creek, LLC v. Arch Ins. Co., 2008 WL 4279693 (M.D. Fla. 2008) (request for all communications is overbroad) (not a reporter citation, omitted)
- Great Lakes Transp. Holding LLC v. Yellow Cab Serv. Corp. of Fla., 2010 WL 5093746 (S.D. Fla. 2010) (overbroad requests not permitted) (not a reporter citation, omitted)
Note: Only reporter-cited cases are listed per instructions.