Bates v. City Of San Jose
- Beth Freeman
- 5:20-cv-07609
- U.S. District Court · Northern District of California
- 2
In Bates v. City of San Jose, Judge Freeman stayed discovery until 30 days after ruling on defendants’ pending motion to dismiss.
The discovery process for Frederick Bates and the defendants in this case was paused; the order particularly addressed the defendants’ request for protection from discovery while their motion to dismiss remained pending.
What happened
In Bates v. City of San Jose, defendants asked the court to pause discovery until 30 days after it ruled on their pending motion to dismiss. The plaintiff did not oppose the request.
The court said a discovery pause may be appropriate when a pending motion could resolve the case or the relevant issue and can be decided without discovery. After reviewing the motion, the court found both conditions met.
Judge Freeman ruled that good cause existed and stayed discovery until 30 days after the court rules on the motion to dismiss. This order did not decide the motion to dismiss or the underlying claims.
The detailed version
- Bates v. City Of San Jose · No. 5:20-cv-07609
- Beth Freeman
- Mar. 11, 2021
Background
At a March 11, 2021 case-management conference, the defendants requested a stay of discovery until 30 days after the court ruled on their pending motion to dismiss. Frederick Bates indicated that he did not oppose the request.
Legal standard
The court explained that district courts have broad discretion to control discovery. Under Federal Rule of Civil Procedure 26(c)(1)(A), a protective order—including a discovery stay—may issue for good cause. Courts in the Northern District of California apply a two-part test: the pending motion must potentially dispose of the entire case, or at least the issue for which discovery is sought, and the motion must be capable of being decided without discovery.
Ruling
After taking the required preliminary review of the defendants’ motion to dismiss, the court found that the motion was potentially dispositive and could be decided without discovery. The court therefore found good cause to stay discovery, concluding that the stay would promote efficiency and protect the defendants from burdensome discovery based on allegations that might not proceed.
The court ordered that discovery in the case was stayed until 30 days after it ruled on the pending motion to dismiss. The opinion does not decide that motion or the merits of the parties’ claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.