Chinchilla v. New York City Police Department
- Ho
- 1:23-cv-08986
- U.S. District Court · Southern District of New York
- 4
Chinchilla v. New York City Police Department: Judge Ho denied discovery sanctions, finding no willful disobedience of discovery orders.
The ruling affects Plaintiff Chinchilla’s request for discovery sanctions and the Defendants’ conduct in producing discovery. The court did not decide the parties’ pending cross-motions for summary judgment.
What happened
In Chinchilla v. New York City Police Department et al., Plaintiff asked the court to impose penalties on Defendants for allegedly failing to provide documents required by discovery orders and requested a discovery conference. The conference was held on September 4, 2024, making that part of the request moot.
Plaintiff argued that Defendants withheld documents about her religious-accommodation request, the citywide vaccine mandate’s accommodation process, information about fetal cell lines in COVID-19 vaccines, and complaints alleging religious discrimination by accommodation decision-makers. Defendants later produced the discovery at issue, and the parties disputed the proper scope and search terms for electronically stored information.
Judge Dale E. Ho denied Plaintiff’s motion for sanctions. He found that Defendants’ earlier failure to produce some documents resulted from legitimate disagreements rather than willful disobedience, and noted that Defendants ultimately produced all discovery to which Plaintiff was entitled.
The detailed version
- Chinchilla v. New York City Police Department · No. 1:23-cv-08986
- Ho
- Aug. 28, 2025
Background
Plaintiff moved under Federal Rule of Civil Procedure 37 for discovery sanctions against Defendants and requested a pre-motion discovery conference under Local Civil Rule 37.2. The court held the requested conference on September 4, 2024, so that portion of the motion became moot.
Plaintiff claimed that Defendants repeatedly failed to comply with the court’s May 23, 2024 and August 9, 2024 discovery orders. She identified three categories of documents: materials concerning her request for a religious accommodation and Defendants’ processes and policies for deciding religious-accommodation requests related to the citywide vaccine mandate; materials concerning the use of aborted fetal cell lines in COVID-19 vaccinations that were provided to reviewers of religious-accommodation requests; and complaints alleging religious discrimination against people who decided Plaintiff’s accommodation requests.
Court’s Analysis
Rule 37 permits a court to impose appropriate orders when a party fails to obey a discovery order. Possible sanctions include treating certain facts as established, preventing a party from supporting or opposing specified claims or defenses, and requiring payment of reasonable expenses unless the failure was substantially justified or other circumstances make an award unjust. The court explained that district courts have broad discretion, but sanctions must be just and are generally reserved for extreme cases and extraordinary circumstances.
The court noted that at least one disputed item, the Citywide Panel Voting Spreadsheet, was produced after the parties’ stipulated protective order was entered. Because production of that spreadsheet had been conditioned on filing a protective order, the court denied any request for sanctions based on the timing of that production.
As to the other documents, the court had previously reserved judgment on sanctions while setting production deadlines and directing the parties to meet and confer in good faith. The parties could not resolve their remaining disputes, which the court addressed at an October 21, 2024 conference. After reviewing those disputes, the court found that Defendants’ earlier failure to produce some documents was not caused by willful disobedience. Instead, it resulted from disagreements about issues including the proper scope and search terms for electronically stored information. The court also found that Defendants ultimately produced all discovery to which Plaintiff was entitled.
Disposition
The court held that Rule 37 sanctions were inappropriate and DENIED Plaintiff’s Motion for Sanctions. The court directed the Clerk of Court to terminate ECF No. 53. It stated that the parties’ cross-motions for summary judgment would be adjudicated later.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.