Hyams v. CVS Health Corporation

Background

Plaintiffs Ryan Hyams and Regine Duhon moved to compel CVS Health Corporation, CVS Pharmacy, Inc., Garfield Beach CVS, LLC, and CVS Rx Services, Inc. (collectively, “CVS”) to lift certain redactions. Magistrate Judge Illman denied that motion on October 8, 2020. Plaintiffs then moved for relief from Judge Illman’s non-dispositive pretrial order.

Legal standard

Under 28 U.S.C. § 636(b)(1)(A), a district court may reverse a magistrate judge’s non-dispositive pretrial order only if the order is “clearly erroneous or contrary to law.” This means the district court does not replace the magistrate judge’s judgment merely because it might have decided the issue differently; reversal requires a clear error or legal mistake.

Ruling

Judge Gilliam stated that he had reviewed Judge Illman’s order, the plaintiffs’ motion, and the relevant legal authorities. He found Judge Illman’s order “well-reasoned and thorough” and affirmed it because it was not clearly erroneous or contrary to law. The court therefore denied the motion for relief from the non-dispositive pretrial order. The opinion refers to this as “Defendant’s motion” in the final disposition, although it identifies the October 22 motion as one filed by the plaintiffs.