Cooper v. The Office of The Commissioner of Baseball
- Vernon Broderick
- 1:24-cv-03118
- U.S. District Court · Southern District of New York
- 4
In Cooper v. The Office of the Commissioner of Baseball, Judge Broderick denied defendants’ request to pause discovery.
The ruling directly affects defendants The Office of the Commissioner of Baseball d/b/a Major League Baseball and PDL Blue, Inc., who sought to pause discovery, and plaintiffs Brandon Cooper and Alexander Lawrie, whose discovery may proceed while the defendants’ other motion is pending.
What happened
In Cooper v. The Office of the Commissioner of Baseball, former MLB employees and aspiring umpires Brandon Cooper and Alexander Lawrie sued, alleging discrimination, harassment, termination, and retaliation under federal and New York laws.
MLB and PDL Blue asked the court to pause discovery while it considered their separate request to dismiss some claims, split the plaintiffs’ claims into separate cases, and transfer them. The defendants argued that discovery should wait, but they acknowledged that the federal Title VII claims would remain even if their other motion succeeded.
Judge Vernon S. Broderick denied the discovery-stay motion. He ruled that the defendants had not shown the required good cause because discovery would still be needed for the Title VII claims, and they had not specifically shown that discovery would be unusually broad or unfairly burdensome.
The detailed version
- Cooper v. The Office of The Commissioner of Baseball · No. 1:24-cv-03118
- Vernon Broderick
- Jan. 9, 2025
Background
Brandon Cooper and Alexander Lawrie, former MLB employees and aspiring MLB umpires, filed the operative complaint on November 6, 2024. They allege that the defendants adopted an unlawful diversity quota under which women would be promoted regardless of merit. They further allege that the policy harmed them and that they were demeaned and terminated after complaining about a female umpire’s sexual harassment.
The complaint asserts hostile-work-environment, wrongful-termination, and retaliation claims under Title VII of the Civil Rights Act, the New York State Human Rights Law, and the New York City Human Rights Law.
Motions and legal standard
The defendants filed a motion seeking to dismiss the New York State and New York City Human Rights Law claims for lack of a connection to New York, sever the plaintiffs’ claims because they allegedly arose from separate transactions or occurrences, and transfer the severed actions to other federal districts.
While that motion was pending, MLB and PDL Blue moved under Federal Rule of Civil Procedure 26(c) for a complete stay of discovery. A discovery stay pauses the exchange of evidence during the case. The party seeking the stay must show “good cause” through a particular and specific factual showing. When a motion to dismiss is pending, courts consider whether the claims appear clearly unmeritorious, how broad and burdensome discovery would be, and the risk of unfair prejudice to the party opposing the stay.
Court’s reasoning
Judge Broderick concluded that none of those factors supported a stay. The defendants conceded that the plaintiffs’ Title VII claims would remain even if the defendants’ separate motion were granted in full. Courts generally do not stay discovery when the pending motion will not potentially dispose of the entire action. The court also noted that some discovery would be needed even if the case were transferred.
The defendants objected generally that the plaintiffs might seek broad discovery concerning MLB’s hiring, disciplinary, and promotion policies. But they did not explain whether dismissing the state and city claims would change the overall scope of discovery or why discovery would be materially different if those claims were dismissed. The court expressly stated that it was not expressing an opinion on the merits of those claims at that time.
Disposition
Judge Vernon S. Broderick DENIED the defendants’ motion for a discovery stay. The clerk was directed to terminate the motion at docket entry 33. The court also stated that a separate order would refer general pretrial matters, including future discovery disputes and requests for extensions, to Magistrate Judge Gary Stein.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.