Huff v. Canterbury Park Holding Corporation

Background

Danny Huff, appearing without a lawyer, sued Canterbury Park Holding Corporation. His operative complaint asserted claims for unpaid wages and retaliation under the Fair Labor Standards Act and Minnesota law. Huff later moved for permission to file a second amended complaint that would add claims and several defendants. Canterbury moved to dismiss the operative complaint. Those motions were pending when Huff asked the court to require a conference under Federal Rule of Civil Procedure 26(f), which generally requires the parties to discuss discovery and propose a discovery plan.

Canterbury opposed Huff’s request and moved to stay, or pause, all discovery and related deadlines until the court ruled on the motion to amend and the motion to dismiss. Canterbury argued that proceeding with discovery could impose substantial costs and might be unnecessary if the dismissal motion succeeded. It also argued that the proposed amended complaint could change the scope of the case. Canterbury pointed to settlement agreements attached to Huff’s complaint and argued that they released the claims and supported dismissal. Huff argued that delaying discovery could prejudice him, including because witnesses’ memories might deteriorate.

Analysis

The court explained that a filing of a dismissal motion does not automatically justify stopping discovery. But a stay may be appropriate when the motion could dispose of all or most of the case, appears to have substantial legal grounds, and avoiding discovery would conserve resources. The court considered Canterbury’s potential hardship, possible prejudice to Huff, judicial efficiency, and Canterbury’s likelihood of success on the dismissal motion.

The court found that Canterbury could face significant and potentially unnecessary discovery costs because Huff’s proposed amended complaint was lengthy and would add claims and defendants. It found that any potential prejudice to Huff was minimal at this procedural stage. The court expected Canterbury to preserve relevant information and found Huff’s concern about unnamed witnesses’ memories insufficient to prevent a stay. The court also found that staying discovery would conserve judicial resources because the parties had not yet held the Rule 26(f) conference, no discovery was pending, and the pending motions could eliminate or change the need for discovery.

Regarding the likelihood of success factor, the court reviewed the release clauses in the settlement agreements but expressly stated that it was not deciding the merits of Canterbury’s motion to dismiss. It found only that Canterbury had shown sufficient likelihood of success to justify pausing discovery.

Order and effect

The court DENIED Huff’s Motion and Memorandum to Compel a Rule 26(f) Conference. It GRANTED Canterbury’s Motion to Stay. The court ordered that all discovery and related deadlines remain stayed pending rulings on Huff’s Motion to Amend and Canterbury’s Motion to Dismiss. The order did not resolve either pending motion or decide whether Huff’s claims were barred by the settlement agreements.

Judge Elizabeth Cowan Wright signed the order on August 22, 2023.