Murphy v. Minnesota Department of Human Services
- Donovan Frank
- 0:16-cv-02623
- U.S. District Court · District of Minnesota
- 8
Murphy v. Harpstead: Judge Thorson denied the defendant’s motion to change discovery deadlines so she could seek absent class members’ financial records.
The defendant’s request to reopen or extend the deadline for seeking absent class members’ financial records was denied. The order left the existing scheduling deadlines in place and did not require the absent class members to produce those records.
What happened
In Murphy v. Harpstead, the defendant asked to change the case schedule so she could renew a request for financial records from people who were not named plaintiffs but were part of the proposed class. The request came after the deadlines for discovery motions had passed.
The court found that the defendant had not acted diligently. She could have asked for an extension before the July 2021 deadline or before the March 2022 deadline, but she waited until March 14, 2022. The court therefore denied the motion to change the schedule and did not need to decide the plaintiffs’ arguments about burden, relevance, or duplication.
Judge Becky R. Thorson ruled that the defendant had not shown the required good cause to amend the scheduling order. The court denied the Motion to Amend Scheduling Order.
The detailed version
- Murphy v. Minnesota Department of Human Services · No. 0:16-cv-02623
- Donovan Frank
- Apr. 1, 2022
Background
The defendant moved to amend the scheduling order. She wanted permission to renew a motion to compel—an application asking the court to require production of documents—seeking financial records from “purported absent class members,” meaning people included in the proposed class who were not named plaintiffs.
Fact discovery had closed in June
- After later supplemental discovery, the court ordered that motions to compel relating to the written discovery identified in the parties’ joint status report had to be filed by July 1,
- The court also required supplemental document production to be completed by September 1, 2021, set deposition periods, and required other motions concerning supplemental fact discovery to be filed by March 1,
- The order stated that discovery could not be taken or produced after February 28, 2022, unless the court granted permission.
In an earlier ruling, the court required updated financial records from named plaintiffs but denied, without prejudice, the request for financial records from purported absent class members. The district court affirmed that ruling. The defendant later renewed her request after depositions and filed this motion to amend the schedule on March 14, 2022.
Arguments
The defendant argued that she could not learn enough about the absent class members’ financial documents until their depositions. She relied on testimony indicating that bank or debit-card records would show when, where, and how much people spent in the community.
The plaintiffs argued that a motion to compel was untimely, that the defendant had not shown good cause for disregarding the deadlines, and that the requested documents were not proportional to the needs of the case and were duplicative.
Court’s analysis
Federal Rule of Civil Procedure 16(b)(4) allows a scheduling order to be modified only for good cause and with the judge’s consent. The court explained that the main measure of good cause is the moving party’s diligence in trying to meet the scheduling order’s requirements. Under the District of Minnesota’s local rule, a party generally also must obtain a hearing date before the deadline it seeks to change passes, unless extraordinary circumstances exist.
The court found that the defendant had not shown diligence. First, she could have asked for an extension before the July 1, 2021 deadline based on her plan to ask about financial documents during depositions. Second, at least one relevant deposition occurred on November 19, 2021, more than three months before the March 1, 2022 deadline, and nearly all depositions were completed before February 18, 2022. Third, the deposition information identified by the defendant provided only general information about what financial records would show—information the court said was known, or should have been known, before the July 2021 deadline.
The court also found that the defendant had not complied with the local rule’s hearing-date requirement. Because the defendant was not diligent and therefore had not shown good cause, the court did not address prejudice to the plaintiffs or their arguments about proportionality and duplication. The court noted that, based on the record before it, its ruling on the request for absent class members’ financial records would remain the same as the earlier ruling.
Disposition
Judge Becky R. Thorson concluded that the defendant had failed to establish good cause to amend the scheduling order. The court denied the defendant’s Motion to Amend Scheduling Order (Doc. No. 812).
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.