Scott v. Dominguez

Background

James Scott, who is housed at Salinas Valley State Prison and is representing himself, filed a civil-rights action under 42 U.S.C. § 1983. Scott alleges that Sergeant Dominquez denied him access to the courts. According to the allegations, Scott received CDs and DVDs containing pretrial discovery materials on or about January 17, 2023. Because prison policy prohibited inmates from possessing CDs and DVDs, the materials were sent to an address in Modesto, even though Scott had asked that they be sent to his attorney. Scott alleges that the materials contained exculpatory evidence, have not been located, and are needed to prepare a federal petition challenging his conviction.

The parties had already conducted some discovery. Scott served a request for production of documents, the defendant responded, and defense counsel deposed Scott. Scott later sent a meet-and-confer letter and additional requests for production and interrogatories.

Request to Stay Discovery

The defendant asked the court to stay, or pause, discovery while his summary-judgment motion was pending. The defendant argued that the motion could dispose of the entire case, that the court did not need additional information to decide it, and that responding to discovery would be an unnecessary expense if summary judgment were granted. The defendant also argued in the summary-judgment motion that Scott had not suffered an actual injury, that Scott had access to the prison law library, that prison policy—not the defendant—caused the alleged injury, and that qualified immunity applied.

The court explained that the Federal Rules of Civil Procedure do not automatically pause discovery whenever a potentially case-ending motion is pending. A complete stay requires good cause, including a showing that discovery would cause annoyance, embarrassment, oppression, or undue burden or expense.

Ruling

The court denied the defendant’s request to stay discovery. It held that the possibility that the summary-judgment motion might end the case was not enough, by itself, to justify a complete stay. The defendant had stated only generally that responding to discovery would waste resources and had not shown that Scott’s requests caused the types of burdens recognized by the rule. The court also noted that it appeared the defendant might not have produced documents in response to Scott’s first request and that the record was unclear about whether responding to the newer requests would create an undue burden or expense.

The order addressed only the request to pause discovery. It did not rule on the summary-judgment motion or decide the merits of Scott’s civil-rights claim. The court denied the request and terminated the associated motion.