Sughrim v. State of New York

Background

The defendants asked the plaintiffs to provide discovery about their religious beliefs, including the basis for their beliefs about maintaining facial hair, religious texts, social-media posts, financial contributions to religious organizations, and communications about their beliefs. The plaintiffs objected that the requests were vague, harassing, overly broad, disproportionate to the needs of the case, and unrelated to the claims or defenses. For requests about financial contributions and communications, they also asserted a First Amendment associational privilege and declined to provide a privilege log.

The defendants argued that the plaintiffs’ religious sincerity was relevant because the plaintiffs continued to seek relief concerning religious accommodations, including accommodations already granted to some plaintiffs and possible future accommodation requests. The defendants also argued that the plaintiffs had not properly answered requests for admission concerning religious beliefs.

Ruling

The court’s endorsement states that the defendants’ letter motion was denied in part as moot because the parties had reached agreement on all but one dispute. As to the remaining dispute, the court granted in part the defendants’ letter motion and ordered the plaintiffs to provide the defendants with a list of all contributions each plaintiff made to any religious organization during the past five years.

Judge Ronnie Abrams found that the sincerity of the plaintiffs’ religious beliefs was at issue in the case. Applying the federal discovery rule requiring information to be relevant and proportional to the needs of the case, the court concluded that the contribution information met that standard. The endorsement does not state a separate disposition of the defendants’ other discovery requests.