Henderson v. Thomas
- Wise
- 5:22-cv-02166
- U.S. District Court · Northern District of California
- 3
In Henderson v. Thomas, Judge Wise denied Henderson’s discovery-stay motion and denied his protective-order request without prejudice.
Plaintiff Johndell Henderson’s request to pause discovery was denied, so discovery must proceed. His separate request concerning personal and legal documents was denied without prejudice, allowing him to submit a properly explained motion.
What happened
In Johndell Henderson v. Michael Thomas, et al., Johndell Henderson, a self-represented state prisoner, asked the court to pause discovery while it ruled on other motions and an appeal. He also cited his visual impairment and requested protection for personal and legal documents.
The court said the other filings and appeal had been resolved, and Henderson had not identified another potentially case-ending motion or shown why discovery could be decided without more information. The court therefore denied the request to stay discovery. It also denied the protective-order request without prejudice because it was unclear what relief Henderson wanted and why he was entitled to it.
Judge Noél Wise ruled that discovery must proceed, while noting that Henderson might be able to seek additional time for future filings if he showed good cause. The court allowed Henderson to file a proper protective-order motion explaining the requested relief and supporting grounds.
The detailed version
- Henderson v. Thomas · No. 5:22-cv-02166
- Wise
- Aug. 18, 2026
Background
Plaintiff Johndell Henderson, a self-represented state prisoner, moved to stay—that is, pause—discovery. Defendants had sent him interrogatories and requests for admissions on March 20, 2026. Henderson asked the court to pause discovery while it ruled on several motions and while his interlocutory appeal was resolved. He also cited his visual impairment.
Henderson additionally sought a protective order concerning personal and legal documents in his possession and documents held in storage by the California Department of Corrections and Rehabilitation.
Court’s Analysis
The court applied Federal Rule of Civil Procedure 26. A discovery stay based on a protective order requires the requesting party to show good cause. For a stay based on a pending motion, the court considers whether the motion could dispose of the entire case, or the issue to which discovery is directed, and whether the motion could be decided without additional discovery.
The court found that Henderson’s cited filings and appeal had been resolved and therefore could no longer support a stay. Henderson had not filed another motion that was potentially dispositive of the case or of an issue targeted by discovery. The court also found his disability argument unpersuasive in light of the numerous motions he had prepared and filed during the preceding year. The court noted, however, that his disability might support a request for additional time to submit future filings if he showed good cause.
Rulings
Judge Noél Wise denied Henderson’s motion to stay discovery. The court stated that discovery must proceed.
The court separately denied Henderson’s request for a protective order without prejudice. It found that the request was vague because Henderson did not explain the relief he sought, why a protective order was needed, or what legal authority supported the request. The denial without prejudice permits Henderson to file a proper motion explaining the specific relief requested and the grounds supporting it. The Clerk was directed to terminate ECF No. 110.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.