3:23-cv-00279
N.D. Tex.May 3, 2024Background
- Sydney Watson was hired by Blaze Media LLC to co-host a political and cultural interview show.
- Watson alleges severe harassment by her co-host, Elijah Schaffer, including misogynistic and anti-Semitic behavior, often while intoxicated.
- Watson claims Blaze Media management was aware of Schaffer’s conduct but failed to investigate or take corrective action, leading to her constructive discharge and eventual termination in 2022.
- Schaffer was later terminated by Blaze Media in September 2022 for policy violations after an internal investigation.
- Watson sued Blaze Media for sex and religious discrimination, retaliation, and wrongful constructive termination under Title VII and the Texas Commission on Human Rights Act.
- During discovery, Watson sought information regarding complaints about Schaffer’s conduct; the court’s order addresses her motion to compel responses to three interrogatories on this subject.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Interrogatory No. 4 – Reasons for Schaffer’s termination | Reasons are central to claims; relevant to whether Schaffer harassed Watson | Reasons are private, irrelevant (Schaffer was terminated post-Watson) | Defendant must answer—reasons are relevant and discoverable |
| Interrogatory Nos. 8 & 9 – Complaints/actions re: Schaffer’s conduct | Info is relevant to Watson’s claims and potential pattern for exemplary damages | Overly broad, privacy issues, requests include irrelevant complaints | Defendant must respond, limited to 2021–2022, sex/religion issues |
| Scope of other complaints about Schaffer | Any complaints of hostile environment/harassment based on sex or religion | Only complaints similar to Watson’s during her tenure | Limit to sex/religion and 2021–2022 only |
| Relevance when Schaffer was not Watson’s supervisor | Co-worker harassment actionable if employer failed to act | Complaints irrelevant since Schaffer wasn’t Watson’s supervisor | Co-worker harassment can be relevant; objections overruled |
Key Cases Cited
- McLeod, Alexander, Powel & Apffel, P.C. v. Quarles, 894 F.2d 1482 (5th Cir. 1990) (party resisting discovery must specifically show how each request is not relevant or is objectionable)
- In re Santa Fe Int'l Corp., 272 F.3d 705 (5th Cir. 2001) (party asserting privilege bears the burden of proving its applicability)
- Royal v. CCC & R Tres Arboles, LLC, 736 F.3d 396 (5th Cir. 2013) (employer liability for co-worker harassment when it knew or should have known and failed to act)