Reese v. Sherburne County Detention Center

Background

Dontay Reese filed a complaint under 42 U.S.C. § 1983 alleging negligence and constitutional-rights violations while he was incarcerated at Sherburne County Detention Center. The defendants had proceeded in two groups: the MEnD Defendants—MEnD Correctional Care, PLLC; Janell Hussain; and Barb Wisniewski—and the Sherburne County Defendants. Reese was representing himself and had filed numerous discovery-related documents.

The claims identified by the court involved denial of access to legal resources, retaliation through additional restrictions on that access, deliberate indifference to a risk of harm related to mental illness, denial of medication, and inadequate medical care.

Discovery Motions

Reese sought supplemental answers to interrogatories in his second set. He asserted that the MEnD Defendants’ answers to all but the first of 24 interrogatories were incomplete, evasive, or supported by improper objections. The court treated two filings with the same title and substantially identical text as one motion and addressed the more complete filing at ECF No. 87. Reese also asked for more time to conduct discovery after the court ruled on the motion to compel.

The MEnD Defendants argued that the interrogatories were vague, ambiguous, overly broad, disproportionate to the needs of the case, known only to Reese, or seeking information that Reese could access equally easily or more easily.

Court’s Analysis

The court explained that discovery generally covers nonprivileged information relevant to a claim or defense and proportional to the needs of the case. Proportionality considers factors such as the importance of the issues, the amount at stake, the parties’ access to information and resources, the importance of the discovery, and whether its burden or expense outweighs its likely benefit. Discovery must also be limited when it is unreasonably cumulative, available from a more convenient or less burdensome source, or sought after the requesting party had an adequate opportunity to obtain it.

The court agreed that some interrogatories were irrelevant or overly broad. For example, it found that the dates when the defendants attended school and the addresses of those schools were not relevant to Reese’s claims or potential defenses. It also found some requests too vague or broad to justify complete answers, including requests about consultations with any medical professional during treatment or the professional relationship with Reese and requests concerning the dates and writings related to Reese’s medical history and test results.

The court further found that most of the interrogatories would require the MEnD Defendants to engage in guesswork and would impose additional burden and expense. The court described the case as concerning the care and treatment Reese did or did not receive while incarcerated. Because the MEnD Defendants had already provided Reese with his medical records, the court found that the interrogatories sought largely duplicative information that Reese could obtain more conveniently, and possibly more accurately, from those records. The court concluded that the parties had identical access to nearly all of the requested information and that the relative burdens favored denying the motion.

Disposition

The court denied Reese’s motions to compel supplemental answers to interrogatories, ECF Nos. 87 and 90. It also denied as moot Reese’s motion for an extension of time to complete discovery, ECF No. 94. The order was signed by United States Magistrate Judge Katherine Menendez.