SLOANE v. GULF INTERSTATE FIELD SERVICES, INC, 4:16-cv-01571

Plaintiff Thomas Sloane sued Gulf Interstate Field Services, initially as a putative collective/class action; court denied class/collective certification on March 24, 2017 and denied reconsideration April 13, 2017.
After decertification the case proceeded on an individualized basis for Sloane’s personal claims only.
Plaintiff served subpoenas on non-parties seeking broad documentary and testimonial materials about Gulf’s contracts with Kinder Morgan and compensation processes for all Gulf employees at Kinder Morgan sites.
Gulf moved for a protective order under Fed. R. Civ. P. 26(c), arguing the subpoenas were overbroad, unduly burdensome, duplicative, and irrelevant to the sole remaining plaintiff’s individual claims.
The court held a telephonic conference, reviewed submissions, and concluded the subpoenas were not sufficiently tailored to Sloane’s individual claims, duplicative of prior productions, and largely economically (not legally) relevant.
The court granted Gulf’s motion: the contested subpoenas were withdrawn, plaintiff ordered to notify recipients, and existing case management deadlines remained in effect.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether subpoenas to non-parties for broad contract and compensation info are permissible after decertification	Discovery needed to support claims and potentially similar collective allegations	Requests are overbroad, unduly burdensome, duplicative, and irrelevant to the individual plaintiff	Denied — subpoenas withdrawn as overbroad, burdensome, and irrelevant post-decertification
Whether discovery scope must be narrowed after class/collective decertification	Seeks broad class-era materials drafted during putative class stage	Scope must be tailored to individual plaintiff’s claims after decertification	Held that discovery must be tailored; many requests must be narrowed
Whether defendant must produce contract terms between it and clients (Kinder Morgan)	Contracts may bear on wage-setting and liability	Contract terms are economically, not legally, relevant and attenuated; not sufficiently probative	Court found contract terms not legally relevant enough to justify burden; protection granted
Whether producing documents would be duplicative given prior productions and depositions	Plaintiff argued need for comprehensive records	Defendant represented it already produced relevant pay records and provided depositions in related suits	Court accepted duplicative-production argument and relied on it in granting protection

Marroquin-Manriquez v. I.N.S., 699 F.2d 129 (3d Cir. 1983) (district court has broad discretion over discovery; reversal requires abuse of that discretion)
In re Fine Paper Antitrust Litig., 685 F.2d 810 (3d Cir. 1982) (appellate review limited absent clear showing of actual and substantial prejudice from court’s docket control)
Halle v. W. Penn Allegheny Health Sys. Inc., 842 F.3d 215 (3d Cir. 2016) (procedures after decertification: decertify and permit named plaintiff to proceed individually; limits on reviving collective claims)
Boeynaems v. LA Fitness Int’l, LLC, 285 F.R.D. 331 (E.D. Pa. 2012) (discovery must be fair and relevant; not required to be perfect)
Hicks v. Arthur, 159 F.R.D. 468 (E.D. Pa. 1995) (discovery responses must meet traditional relevancy and burden standards)
Kresefky v. Panasonic Commc’ns & Sys. Co., 169 F.R.D. 54 (D.N.J. 1996) (discovery scope is limited and should be tailored to case issues)
Bell v. Lockheed Martin Corp., 270 F.R.D. 186 (D.N.J. 2010) (party seeking discovery must first show relevance)
In re Rail Freight Fuel Surcharge Antitrust Litig., 258 F.R.D. 167 (D.D.C. 2009) (extensive class-stage discovery may be wasted if class certification is denied; scope may shrink post-decertification)