Godfrey v. State Farm Fire and Casualty Company
- Joan Ericksen
- 0:18-cv-00524
- U.S. District Court · District of Minnesota
- 11
In Godfrey v. State Farm, Judge Leung granted State Farm’s discovery motion in part, denied it in part, and denied its request for fees and costs.
Courtney Godfrey and Ryan Novaczyk must provide the ordered discovery and deposition dates, subject to the listed exceptions. State Farm may obtain the permitted discovery but did not receive reimbursement of its fees and costs. Government Employers Insurance Company is a defendant in the underlying case but was not the movant on this order.
What happened
Courtney Godfrey and Ryan Novaczyk sued State Farm Fire & Casualty Company and Government Employers Insurance Company after a boating accident in which Godfrey lost part of her leg. They seek a ruling that insurance provisions excluding coverage for certain family members are invalid under Minnesota law. State Farm asked the court to require responses to its written questions and document requests, and to require both plaintiffs to provide deposition dates.
The court ruled that the plaintiffs had waived most objections because they did not timely respond to the discovery or seek a protective order. It also found that much of the requested information was relevant to the allegations and to whether the plaintiffs had a valid claim and a concrete injury. The court therefore required the plaintiffs to provide discovery responses and deposition dates within 21 days, but excluded requests seeking information only about the amount and type of damages. The court also found that the amount in dispute was sufficient for federal jurisdiction.
Judge Leung granted State Farm’s motion to compel in part and denied it in part. The court denied State Farm’s request for reimbursement of its costs and attorney fees because discovery was limited and the parties had genuinely disagreed about the proper scope of discovery.
The detailed version
- Godfrey v. State Farm Fire and Casualty Company · No. 0:18-cv-00524
- Joan Ericksen
- Feb. 13, 2019
Background
Courtney Godfrey and Ryan Novaczyk sued State Farm Fire & Casualty Company and Government Employers Insurance Company after a boating accident that resulted in the amputation of Godfrey’s leg. They seek a declaration that “resident family member exclusion” provisions in insurance policies issued to Novaczyk are unlawful under Minnesota public policy. The plaintiffs allege that the insurers denied Godfrey liability coverage for injuries from the accident.
State Farm served written discovery and sought to depose both plaintiffs. The plaintiffs said they intended to seek a protective order but did not file one, did not identify deposition dates, and did not respond or object to the discovery. State Farm moved to compel responses, deposition dates, and payment of its costs and attorney fees.
Subject-Matter Jurisdiction
The court had previously questioned whether the amount in controversy exceeded the $75,000 threshold for federal jurisdiction based on the parties’ diverse citizenship. Godfrey submitted an affidavit stating that the value of the requested declaration exceeded $3 million and that she intended to seek the full amount of her damages in a later tort action if she prevailed. The court concluded that the affidavit was sufficient to satisfy the amount-in-controversy requirement.
Discovery Ruling
The court held that the plaintiffs waived most objections to State Farm’s written discovery by failing to object or seek protection on time. It found no good reason to excuse that waiver. The court also found that the discovery was relevant to the factual allegations in the amended complaint, including the accident, Godfrey’s injuries, medical expenses, lost earnings, pain, and damages.
The court rejected the plaintiffs’ position that they could withdraw or modify allegations merely by saying so in response to the motion to compel. The plaintiffs had not moved for permission to amend their complaint, and the court would not treat their statements as an amendment. The court also rejected the suggestion that the plaintiffs could ask the court to strike their own allegations as a discovery sanction to avoid responding to discovery.
The court further held that State Farm could seek factual information relevant to the requested declaration. That included information about whether an insurance policy existed, applied to the plaintiffs, and covered a concrete injury likely to be addressed by the requested declaration. State Farm could also seek information showing that the plaintiffs had a valid underlying legal claim. But the plaintiffs did not have to prove every element or the exact damages of a possible underlying tort action. The court therefore prohibited discovery concerning matters related only to the amount and type of damages that might be sought in that action.
Fees and Costs
State Farm also sought reimbursement of the reasonable costs and attorney fees incurred in bringing the motion. Although the discovery rules generally require such an award when a motion to compel is granted, the court concluded that an award would be unjust because it was limiting the discovery and the parties had a good-faith disagreement about the proper scope of discovery in a declaratory-judgment case.
Disposition
The court ordered the plaintiffs to provide full and complete discovery responses within 21 days, subject to the specified exceptions, and to identify dates within 21 days when they were available for deposition and then appear on those dates. Godfrey was not required to answer specified requests, including requests seeking documents related only to damages, and Novaczyk was excused from specified damages-related document requests. The court denied State Farm’s motion for reimbursement of fees and costs. The order states that the motion to compel was granted in part and denied in part.
Read the full 11-page opinion on CourtListener, the free public archive maintained by the Free Law Project.