Robbins v. Candy Digital, Inc.

Background

Defendants Candy Digital Inc., Scott Lawin, and Anthony Fitzgerald, referred to collectively as the “Candy Defendants,” moved to stay, or pause, all discovery while the court considered their separately filed motion to dismiss Charles Robbins’s First Amended Complaint. Their dismissal motion relied on collateral estoppel, a legal rule that can prevent a party from relitigating an issue already decided in an earlier proceeding.

The motion relied on a January 21, 2025, decision by the New York Supreme Court rejecting Robbins’s challenge to an administrative finding. That finding stated that Robbins was terminated as part of a reduction in force based on performance issues, rather than because of his familial or caregiver status. The Candy Defendants argued that giving the state-court determination preclusive effect would bar most, if not all, of Robbins’s claims in this case.

Court’s Analysis

The court explained that it could stay discovery for good cause while deciding a motion to dismiss. It considered the breadth of the discovery sought, potential prejudice from a stay, and the strength of the dismissal motion.

The court found that discovery would be burdensome if the case were not stayed and might ultimately prove unnecessary. It also noted that numerous discovery issues remained outstanding. Because of delays already present in the case, the court concluded that Robbins had not shown he would be prejudiced by the short delay needed to decide the dismissal motion.

Ruling

The court granted the Candy Defendants’ motion to stay all discovery. The stay will expire when the court issues an order sustaining the amended complaint, in whole or in part. Within seven days of such an order, the parties must submit a proposed revised Case Management Plan and Scheduling Order.