Rubalcava v. City Of San Jose
- Beth Freeman
- 5:20-cv-04191
- U.S. District Court · Northern District of California
- 3
In Rubalcava v. City Of San Jose, Magistrate Judge Freeman denied defendants’ request to deem admissions established or require new answers.
Lionel Rubalcava and the defendants—City of San Jose, Joseph Perez, Topui Fonua, Steven Spillman, Rafael Nieves, and Ramon Avalos—were affected. The defendants were not granted an order deeming Requests for Admissions Nos. 27–44 admitted or requiring Rubalcava to admit or deny them.
What happened
Rubalcava v. City Of San Jose concerns a dispute over Lionel Rubalcava’s responses to requests for admissions about information allegedly disclosed before his 2003 attempted-murder trial.
Rubalcava objected that the requested information was outside his knowledge and held by third parties. He admitted some underlying facts but explained why he could not admit or deny the broader requests. The defendants argued that the evidence required admissions.
The court ruled that Rubalcava’s responses to Requests for Admissions 27–44 complied with the governing rule and denied the defendants’ request. Magistrate Judge Beth Freeman did not require Rubalcava to admit or deny those matters.
The detailed version
- Rubalcava v. City Of San Jose · No. 5:20-cv-04191
- Beth Freeman
- May 22, 2023
Background
Lionel Rubalcava asserts federal constitutional and state-law claims arising from his 2003 wrongful-conviction claim concerning the attempted murder of Raymond Rodriguez. One claim alleges that the defendants withheld material exculpatory and impeachment evidence from prosecutors and the defense, including specified categories of information.
The defendants served Requests for Admissions Nos. 27–44 seeking to establish that some information Rubalcava says was withheld had actually been disclosed to his criminal defense counsel before trial. Rubalcava did not simply admit or deny the requests. Instead, he objected that the requests sought information outside his knowledge and uniquely within third parties’ custody, admitted certain subsidiary facts, and explained why he lacked enough information to admit or deny the requests at that time.
Rule and analysis
Federal Rule of Civil Procedure 36 requires a party to answer or object to a request for admission within 30 days. If the party does not admit the matter, the response must specifically deny it or explain in detail why it cannot truthfully admit or deny it. A party may rely on lack of knowledge or information only after making a reasonable inquiry and determining that the information it knows or can readily obtain is insufficient.
The defendants argued that Rubalcava lacked a good-faith basis to refuse to admit or deny the requests because the defendants’ evidence supposedly established the requested facts unequivocally. The court concluded that Rubalcava’s responses were not based on mere uncertainty. He conceded some subsidiary facts, explained why those facts did not compel the requested admissions, and described in detail his position. The court was not persuaded that he had failed to comply with Rule 36.
Disposition
The court concluded that Rubalcava’s responses to Requests for Admissions Nos. 27–44 satisfied Rule 36. It denied the defendants’ request for an order deeming those matters admitted or requiring Rubalcava to admit or deny them. Magistrate Judge Beth Freeman resolved the matter without oral argument.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.