Wood v. Contra Costa County

Background

The court considered Andrea Wood's motion, filed April 23, 2021, and titled “Discovery Requested.” The opinion does not describe the underlying claims in the federal case. The motion sought discovery and, in part, asked the court to require the state court conducting dependency proceedings to provide “all evidence, all testimony, [and] full case files.”

Rulings

The court divided the motion into two requests:

1. Discovery from parties in the federal case: To the extent Wood sought an order requiring a party in the federal case to provide discovery, the court denied the motion without prejudice. The court stated that Wood must first seek discovery from the defendants and cited Federal Rule of Civil Procedure 34, which sets out a procedure for requesting documents in another party's possession.

2. Records from the state court: To the extent Wood sought an order requiring the state court conducting the dependency proceedings to provide evidence, testimony, and case files, the court denied the motion. It held that it lacked jurisdiction—the legal authority to act—to reverse the state court's denial of Wood's request for those documents. The court relied on the rule that federal district courts have no power to review state-court decisions.

Disposition

The court denied the discovery motion as described above: the request for discovery from federal-case parties was denied without prejudice, while the request directed at the state court was denied because the federal court lacked jurisdiction. Judge Maxine M. Chesney entered the order on April 27, 2021.