Smartmatic USA Corp. v. Lindell

Background

This order addressed cross-motions to compel discovery in Smartmatic’s lawsuit alleging defamation and violations of the Minnesota Deceptive Trade Practices Act. The court’s jurisdiction was based on the parties’ diversity of citizenship. Smartmatic sought responses to requests for production, while Lindell and My Pillow sought initial disclosures and answers to interrogatories.

The court explained that discovery must concern nonprivileged information relevant to a claim or defense and proportional to the needs of the case. Because the claims were governed by Minnesota substantive law, the court considered the elements of defamation and deceptive trade practices when deciding whether the requested discovery was relevant.

Smartmatic’s Motion to Compel

Smartmatic sought information about Lindell’s finances, ownership interests, audits, and loans from 2020 to the present. Smartmatic argued that the information was relevant to Lindell’s alleged financial motive, actual malice, and punitive damages. For a public-figure defamation claim, “actual malice” means knowledge that a statement was false or reckless disregard for whether it was false.

The court concluded that Smartmatic properly pleaded its punitive-damages request. It held that Federal Rules of Civil Procedure 8 and 15, rather than the Minnesota statutory procedure for adding punitive damages, supplied the applicable pleading requirements. The court found that the federal and state procedures conflicted and that Smartmatic’s request complied with the federal rules.

The court also held that Lindell’s financial status was relevant to Smartmatic’s actual-malice claim. It therefore granted Smartmatic’s motion as to Requests for Production Nos. 30, 31, 32, and 33. The order’s conclusion states that Smartmatic’s motion to compel was GRANTED.

Defendants’ Motion to Compel

The court granted defendants’ motion as to Smartmatic’s initial disclosures. Smartmatic was ordered to provide a good-faith estimate of its claimed economic and punitive damages, with the understanding that the estimate could change as discovery continued. At the close of discovery, Smartmatic was required to provide a finalized computation of each damages category under Rule 26.

The court granted defendants’ motion as to Interrogatory No. 20. Smartmatic was ordered to provide a list of jurisdictions that would not or might not do business with Smartmatic and to supplement that response with relevant expert-discovery information before all discovery closed.

The court also ordered Smartmatic to supplement its responses to Interrogatory Nos. 14 and 15 within 30 days. Those interrogatories sought the identities of people with knowledge about specific allegations concerning Smartmatic’s work with other voting-technology companies during the 2020 election. The court found the requested information relevant and proportional.

The court delayed further responses to Interrogatory Nos. 1, 5, 6, 7, 8, 9, 10, 11, 17, and 18 until expert discovery concluded. The conclusion states that defendants’ motion to compel was GRANTED in part and DENIED in part.