Johnson v. City of Santa Rosa
- Jacquelyn Corley
- 3:23-cv-02478
- U.S. District Court · Northern District of California
- 5
In Johnson v. City of Santa Rosa, Judge Corley denied the defendants’ motions to compel discovery and for sanctions.
The order affected John Paul Johnson and the City of Santa Rosa, Officer Cody Sousa, Officer Christopher O’Neill, and Sergeant Hector Deleon by denying the defendants’ discovery and sanctions motions.
What happened
In Johnson v. City of Santa Rosa, the defendants asked the court to require John Paul Johnson to answer discovery requests and to impose sanctions after his responses were late. Johnson’s lawsuit includes claims about excessive force and false arrest, among others.
Johnson provided the requested discovery on July 8 and 9, 2024. Because the defendants had received the responses, the court said there was nothing left to compel and denied that motion as moot.
Judge Jacqueline Scott Corley also denied the request for sanctions. She found that the defendants had not followed the court’s required process for discussing and jointly presenting discovery disputes, and that both sides contributed to the circumstances surrounding the late responses.
The detailed version
- Johnson v. City of Santa Rosa · No. 3:23-cv-02478
- Jacquelyn Corley
- July 25, 2024
Background
John Paul Johnson brings an excessive-force action against the City of Santa Rosa and four individual defendants. His claims include excessive force and false arrest under 42 U.S.C. § 1983, battery, violation of California’s Bane Act, negligence, and false imprisonment. The opinion describes allegations that officers injured Johnson’s elbow while arresting him and then handcuffed him despite knowing about the injury.
The defendants served special interrogatories and requests for production of documents on May 8, 2024. Johnson’s responses were due June 7, 2024, but he did not respond by that date. The defendants filed a motion to compel and requested sanctions under Federal Rule of Civil Procedure 37. Johnson opposed the motion, stating that the parties had discussed giving him more time and that he would provide responses by July 8, 2024.
Motion to Compel
Johnson produced the requested discovery on July 8 and 9, 2024. Because the defendants had received the discovery responses, the court concluded that there was nothing left for it to compel. The court therefore DENIED the motion to compel as moot.
Motion for Sanctions
The defendants sought attorney’s fees as sanctions for Johnson’s failure to provide timely discovery responses. The court concluded that awarding sanctions would be unjust.
First, the defendants had not followed the court’s standing order for discovery disputes. The order required counsel to meet and confer in person or by videoconference and to submit a joint discovery-dispute statement. The defendants instead proceeded without satisfying those requirements.
Second, the court found that the defendants’ own conduct contributed to the urgency they cited. They served the maximum number of interrogatories per defendant and 84 document requests about a month before fact discovery closed. Johnson indicated that he needed additional time, although he should have requested an extension before the response deadline passed. The court concluded that both sides were at fault and DENIED the motion for sanctions.
Disposition
Judge Jacqueline Scott Corley DENIED the defendants’ motion to compel Johnson’s responses as moot and DENIED the defendants’ motion for sanctions. The order terminated Docket No. 44.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.