Steel Erectors, Inc. ex rel. United States v. AIM Steel International, Inc.
312 F.R.D. 673
S.D. Ga.2016Background
- Plaintiff sued AIM for breach of contract over unpaid work on two federal construction projects. AIM is a U.S. entity owned by a foreign parent (a Panamanian foundation).
- Plaintiff moved to compel AIM to disclose its foreign parent in its Federal Rule of Civil Procedure 7.1 corporate disclosure statement and in interrogatory responses. (Docs. 11, 16)
- AIM sought to seal its parent’s identity under Local Rule 79.7, arguing disclosure would harm its competitive position in the international steel fabrication market by lowering entry barriers. (Doc. 17)
- AIM responded in interrogatory answers that its parent had no involvement in the two projects and provided no funding, but objected to providing the parent’s contact information as irrelevant and disproportionate. (Doc. 20)
- The parties jointly moved for a 75-day discovery extension in case disclosure allowed further parent-focused discovery. (Doc. 18)
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether AIM may seal its corporate-disclosure statement to avoid naming its foreign parent under Rule 7.1 | Disclosure required by Rule 7.1; public interest in judicial openness and recusal outweighs privacy/competitive concerns | Sealing necessary to protect competitive advantage and keep capital sources private to preserve market entry barriers | Denied motion to seal; granted plaintiff’s Rule 7.1-related compel — AIM must file unredacted disclosure naming any parent within 7 days |
| Whether AIM must supplement interrogatory responses with parent identity/contact and related discovery about parent involvement/funding | Parent identity/contact relevant to discover whether parent caused or funded breaches; needed to pursue claims against parent | Parent had no involvement or funding for the projects; identity/contact not relevant or proportional to needs; international discovery would be burdensome | Denied plaintiff’s motion to compel further interrogatory responses (parent contact and related discovery) as not relevant/proportional given AIM’s representations |
| Whether to extend discovery 75 days pending possible parent-related discovery | Extension warranted if parent disclosure opened new discovery avenues | Extension unnecessary because court limited parent discovery by denying interrogatory compel; potential future motions remain available | Denied the joint motion to extend discovery 75 days |
Key Cases Cited
- Press-Enter. Co. v. Sup. Ct. of Cal. for Riverside Cty., 478 U.S. 1 (1986) (public access to judicial processes plays a significant positive role)
- Hickman v. Taylor, 329 U.S. 495 (1947) (scope of discovery includes all relevant, nonprivileged information)
- Chudasama v. Mazda Motor Corp., 123 F.3d 1353 (11th Cir. 1997) (claims and defenses define discovery scope)
- United States v. Capers, 708 F.3d 1286 (11th Cir. 2013) (definition of relevance: evidence with any tendency to make a fact more or less probable)
- Romero v. Drummond Co., 480 F.3d 1234 (11th Cir. 2007) (court operations and judicial conduct are matters of strong public concern informing disclosure/recusal interests)
- United States v. Sattar, 471 F. Supp. 2d 380 (E.D.N.Y. 2007) (example of defining a "higher interest" justifying sealing)