Caldwell v. Willis Towers Watson US LLC

Background

Plaintiff Scott Caldwell filed a letter motion asking for a conference to resolve a discovery dispute. He sought information about other employees’ discrimination complaints and how other employees were treated when they returned from extended leaves of absence.

Court’s Analysis

The court found the requests overbroad, unduly burdensome, and not proportional to the needs of the case. Caldwell’s complaint alleged actions taken against him by his direct supervisors, Julie Gebauer and Doug Friske. It did not allege a company-wide discrimination policy or practice. The court explained that when an individual plaintiff does not allege company-wide discrimination, courts have been hesitant to allow discovery into all company-wide complaints.

The court also found that requests for unspecified complaints of discrimination against the defendant were not proportional because the defendant had thousands of employees across multiple offices, making it likely that many complaints would have no factual connection or relevance to Caldwell’s case. A request for information about all leaves of absence exceeding 30 days was also irrelevant because Caldwell did not allege that he had been denied leave, and the request implicated other employees’ privacy.

The court further noted that the defendant had already answered the relevant question: whether Gebauer and Friske had been the subject of an administrative claim, petition, charge, arbitration, lawsuit, complaint, or other litigation alleging employment discrimination or retaliation during at least the previous five years.

Disposition

Magistrate Judge Ona T. Wang denied Caldwell’s letter motion. The Clerk of Court was directed to close ECF 47. The court reminded the parties that it could apportion costs under Federal Rules of Civil Procedure 16, 37(a)(5)(A)-(C), and 37(b), 28 U.S.C. § 1927, and the court’s inherent authority.