Toyota Motor Sales v. Interchange
Toyota Motor Sales, U.S.A., Inc. v. Allen Interchange, LLC, Applegate Supply, Patriot Parts of Texas, Bluestone Auto Products, OEM Parts Company, Factory Parts Direct, Autoworks Distributing, and Defendants DOES 1–10
- Katherine Menendez
- 0:22-cv-01681
- U.S. District Court · District of Minnesota
- 3
Counsel of record per CourtListener. Firm names are approximate and have been consolidated across spelling variants.
In Toyota Motor Sales v. Allen Interchange, Judge Menendez upheld two magistrate judge discovery orders that blocked Toyota from serving dealer subpoenas and compelling a specific interrogatory response.
Toyota Motor Sales, U.S.A., Inc. and Toyota Motor North America, Inc., who lose their challenge to two discovery rulings and remain unable to subpoena third-party Toyota dealerships or compel a specific interrogatory response from Allen Interchange. Allen Interchange and the other defendants benefit from the affirmance, keeping those discovery limits in place.
What happened
In Toyota Motor Sales, U.S.A., Inc. v. Allen Interchange, LLC et al. (No. 22-cv-1681), Toyota sued Allen Interchange and several other defendants — apparently over automotive parts — and the case generated a counterclaim by Allen Interchange against Toyota entities. The dispute in this order centers entirely on discovery (the pre-trial process of gathering evidence and information): Toyota challenged two rulings by Magistrate Judge John F. Docherty that limited what information Toyota could collect. The first ruling blocked Toyota from sending formal information-gathering demands (subpoenas) to third-party Toyota dealerships, finding that Toyota could get the needed documents from Allen itself. The second ruling denied Toyota's request to force Allen to answer a specific written question (Interrogatory No. 39), finding the request improper based on earlier rulings.
Toyota argued that both rulings were wrong. On the dealer subpoenas, Toyota said the magistrate judge incorrectly assumed Allen had the documents when evidence showed Allen did not have them or had destroyed them, and that the judge wrongly accepted Allen's unsupported concern that subpoenas would intimidate dealers. On the interrogatory, Toyota said the judge mistakenly relied on a prior ruling that addressed different information and failed to properly assess why the requested information was relevant to the case.
Judge Katherine Menendez applied the standard required when reviewing a magistrate judge's non-final discovery order: she could only overturn it if it was 'clearly erroneous or contrary to law' — a very high bar described in case law as 'extremely deferential.' After reviewing the underlying orders, the hearing transcript, Toyota's challenges, and Allen's responses, Judge Menendez found that neither discovery order crossed that threshold. She overruled Toyota's objections and affirmed both of Magistrate Judge Docherty's orders.
The detailed version
- Toyota Motor Sales v. Interchange · No. 0:22-cv-01681
- Katherine Menendez
- Feb. 26, 2026
Background
Toyota Motor Sales, U.S.A., Inc. originally sued Allen Interchange, LLC and several other defendants — Applegate Supply, Patriot Parts of Texas, Bluestone Auto Products, OEM Parts Company, Factory Parts Direct, and Autoworks Distributing — as well as unnamed Doe defendants. Allen Interchange filed counterclaims against Toyota Motor Sales, U.S.A., Inc. and Toyota Motor North America, Inc. (together referred to in the order as "Toyota"). The opinion does not describe the underlying substantive claims, so the nature of the dispute (e.g., trademark, parts supply, breach of contract) cannot be stated with certainty from this order alone.
The Two Challenged Discovery Orders
This order addresses Toyota's objections — treated as appeals under Federal Rule of Civil Procedure 72(a) — to two nondispositive (non-final) rulings issued by United States Magistrate Judge John F. Docherty.
First Appeal: November 26, 2025 Order on Third-Party Dealer Subpoenas (Dkt. 759)
Toyota sought to serve subpoenas (formal court-backed demands for documents or testimony) on third-party Toyota dealerships. Magistrate Judge Docherty denied this relief. Toyota argued the denial rested on two errors: (1) the magistrate judge incorrectly concluded Toyota could obtain the requested documents from Allen Interchange, even though evidence suggested Allen did not possess or had destroyed the responsive materials; and (2) the magistrate judge wrongly found that the subpoenas would have an in terrorem (intimidating) effect on dealers, based solely on Allen's speculation and contrary to the record evidence.
Second Appeal: December 4, 2025 Order on Interrogatory No. 39 (Dkt. 769)
Toyota also moved to compel Allen Interchange to answer Interrogatory No. 39, a specific written discovery question. Magistrate Judge Docherty denied that motion as well. Toyota contended that the denial was erroneous because: (1) the magistrate judge improperly relied on a prior ruling addressing requests for different information than what Interrogatory No. 39 sought; and (2) the magistrate judge failed to conduct an adequate relevance analysis specific to the information Interrogatory No. 39 requested.
Standard of Review
Under Federal Rule of Civil Procedure 72(a) and District of Minnesota Local Rule 72.2(a)(3), a district judge reviewing a magistrate judge's non-dispositive order must affirm unless the order is "clearly erroneous or contrary to law." The opinion cites Subramanian v. Tata Constituency Servs., Ltd., 352 F. Supp. 3d 908, 919 (D. Minn. 2018), for the characterization of this standard as "extremely deferential."
Ruling
Judge Menendez reviewed the two underlying discovery orders, the full motion practice and relevant docket entries associated with each, the hearing transcript, Toyota's objections (Dkts. 785 and 786), and Allen's responses (Dkts. 788 and 797). She concluded that neither order met the demanding threshold for reversal — neither was clearly erroneous or contrary to law. Accordingly, she overruled Toyota's objections and affirmed both of Magistrate Judge Docherty's orders.
Disposition
- Toyota's Objections (Dkts. 785 and 786): OVERRULED - Discovery Orders (Dkts. 759 and 769): AFFIRMED
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.