MacDermott v. Shelabarger

Background

Defendant Benjaman Shelabarger moved to compel discovery from Plaintiff Troy MacDermott. Shelabarger’s February 3, 2025 requests sought copies of legal filings and responses concerning the Bureau of Prisons, the Federal Medical Center in Rochester, staff members, the December 31, 2023 events involved in the case, and the service dog at issue. He also requested a statement of relevancy that MacDermott had been directed to provide concerning a subpoena served on Warden Jared Rardin.

MacDermott objected, arguing that the requested documents were public records that Shelabarger could obtain himself, that he had already provided a memorandum and docket list summarizing the documents, and that he was not required to finance Shelabarger’s litigation. Shelabarger contended that MacDermott had not properly responded and had instead sent him a religious tract and a notice of intent to seek sanctions.

Legal Standard

Under Federal Rule of Civil Procedure 26, parties may obtain discovery about nonprivileged matters that are relevant to a claim or defense and proportional to the needs of the case. A party seeking an order compelling discovery must show that the other party failed to provide the requested documents or an adequate response. The responding party generally bears the expense of complying with discovery, although the court may issue protection from undue burden or expense.

Court’s Analysis

The court found that Shelabarger’s requests were relevant and proportional because the documents were necessary for him to defend against MacDermott’s allegations. The requests were limited to records concerning the December 31, 2023 events or the service dog and therefore were not unduly burdensome.

The court also found MacDermott’s responses deficient because he had not provided the specifically requested information or offered a reasonable explanation for not doing so. The court rejected MacDermott’s request to shift production costs to Shelabarger. It explained that MacDermott, as the person who brought the federal lawsuit, had to bear the cost of producing the requested documents. The court also noted that some requested records were administrative Bureau of Prisons disciplinary records that were not typically publicly accessible.

Disposition

The court GRANTED Defendant Benjaman Shelabarger’s Motion to Compel. It ordered Plaintiff Troy MacDermott to fully respond to the February 3, 2025 discovery requests by April 21, 2025. The order did not dismiss the case, but it stated that the court may impose sanctions, including dismissal under Federal Rules of Civil Procedure 16(f), 37, or 41(b), if MacDermott fails to comply.