Sabic-El-Rayess v. Teachers College, Columbia University

Background

The plaintiff served discovery requests, including requests for electronically stored information, or ESI. Teachers College searched email accounts for several custodians and produced more than 1,100 pages of responsive documents covering August 2020 through August 2024. The college also agreed to conduct additional searches covering January 1, 2020, through the present, including searches of custodians who had not previously been searched.

The plaintiff then sought additional searches for emails from 2012 through 2015, including searches involving two of twelve custodians. The plaintiff asserted that events from 2012 and 2013—when she was denied tenure-track positions—were relevant background evidence and could help show that later denials were motivated by religion. The supplied text does not include the plaintiff’s letter motion itself; the plaintiff’s position is described in Teachers College’s response.

Arguments

Teachers College argued that the requested time period was overbroad and unduly burdensome. It maintained that the plaintiff had not identified a connection between the earlier tenure-track applications and alleged denials of tenure-track or tenured positions from 2020 onward. The college also argued that the earlier events could not establish protected activity for a later retaliation claim.

Ruling

Judge Jesse M. Furman substantially denied the plaintiff’s letter motion to compel. The court concluded that, given the passage of time and the absence of evidence connecting the events from more than a decade earlier to the plaintiff’s claims, the requested materials were not relevant. The court further stated that, to the extent the materials were relevant, the requested discovery was not proportional to the needs of the case under Federal Rule of Civil Procedure 26(b)(1).

The clerk was directed to terminate ECF No. 78, the docket entry for the letter motion.