Castro-Jacques v. Lang-Nelson Associates, Inc.
- Paul Magnuson
- 0:18-cv-03376
- U.S. District Court · District of Minnesota
- 3
In Castro-Jacques v. Lang-Nelson Associates, Judge Magnuson denied Castro-Jacques’s appeal and affirmed a discovery order refusing requested vehicle photographs.
The ruling affected Michael K. Castro-Jacques’s requested discovery and addressed the privacy interests of residents whose vehicles were in the apartment complex’s parking lot.
What happened
In Castro-Jacques v. Lang-Nelson Associates, Michael K. Castro-Jacques appealed part of a magistrate judge’s discovery order. The earlier order had granted part and denied part of his request to compel information from Lang-Nelson Associates, Inc., Broadway Village Investors, LLC, and Summit/Broadway Limited Partnership.
Castro-Jacques challenged the refusal to let him photograph cars in the parking lot of his former apartment complex. He wanted to photograph vehicles that he said were in the same or similar condition as his vehicle when the defendants towed it. He argued that the photographs could show that similar vehicles were not towed because their residents did not have a disability or ask to end their leases early because of a disability.
Judge Magnuson denied the appeal and affirmed the magistrate judge’s order. He ruled that the requested photographs were not relevant as presented, that Castro-Jacques had not explained how he would identify comparable vehicles or determine the owners’ disability-related circumstances, and that the request raised residents’ privacy concerns. The court said Castro-Jacques had not shown that the earlier order was clearly wrong or contrary to law.
The detailed version
- Castro-Jacques v. Lang-Nelson Associates, Inc. · No. 0:18-cv-03376
- Paul Magnuson
- Apr. 21, 2020
Background
The matter came before the district court on Michael K. Castro-Jacques’s appeal of Magistrate Judge Leo I. Brisbois’s March 25, 2020, order. That order granted in part and denied in part Castro-Jacques’s motion to compel discovery. He appealed only the portion refusing to allow him to photograph cars in the parking lot of his former apartment complex.
Castro-Jacques asked the district court to modify the order so he could photograph vehicles in the same or similar condition as his vehicle when the defendants towed it. The magistrate judge’s order had found that demonstrative photographs of the parking lot were permissible even if residents’ cars happened to appear in them, but it had not found that photographs of other cars would be relevant.
Issue and analysis
The district court reviewed the magistrate judge’s ruling under the standard applicable to nondispositive matters: whether the order was clearly erroneous or contrary to law. Under that deferential standard, the district court gave substantial deference to the magistrate judge’s decision.
The court concluded that the requested photographs were not relevant to Castro-Jacques’s claims as he described them. The court noted that nearly three years had passed since the defendants towed his vehicle. Castro-Jacques did not explain how he would determine which vehicles were in the same or similar condition, or whether he and the defendants would have to agree on that assessment. He also did not explain how he would determine whether the owner of a particular vehicle had a disability or had asked the apartment complex to take action because of a disability. The court further noted that he did not describe how he would address the privacy concerns of the residents.
Ruling
Judge Paul A. Magnuson held that Magistrate Judge Brisbois’s order appropriately balanced Castro-Jacques’s need for information against the limits of the federal discovery rules and the privacy concerns of the defendants’ residents. The court found that Castro-Jacques had not shown that the order was clearly erroneous or contrary to law.
The court therefore denied Castro-Jacques’s appeal and affirmed Magistrate Judge Brisbois’s order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.