Saavedra v. City of New York
- John Cronan
- 1:19-cv-07491
- U.S. District Court · Southern District of New York
- 2
In Saavedra v. City of New York, Judge Cronan ordered an in-camera review of officers’ unredacted disciplinary histories before deciding what must be produced.
Yajaira Saavedra and the defendants, particularly the defendant officers whose disciplinary histories were at issue. The order required defendants to submit those materials to the court for private review and set limits on potentially discoverable information.
What happened
In Saavedra v. City of New York, Yajaira Saavedra asked the court to require defendants to produce unredacted disciplinary summaries for defendant officers. She argued that New York’s repeal of a law protecting those records removed any basis for withholding them.
The defendants responded that the repeal did not change the federal discovery rules and argued that the redacted information was irrelevant to Saavedra’s claims. The court explained that discovery covers relevant, nonprivileged information that is appropriate to the needs of the case. Disciplinary information unrelated to the alleged conduct generally is not discoverable, while information similar to the incident or bearing on the officers’ credibility may be relevant.
The court did not expressly grant or deny the motion. Instead, Judge John P. Cronan ordered the defendants to submit the unredacted disciplinary histories and the redacted copies already produced for private court review. The court would use that review to determine which portions fall within the permitted scope of discovery.
The detailed version
- Saavedra v. City of New York · No. 1:19-cv-07491
- John Cronan
- Dec. 16, 2020
Background
Yajaira Saavedra moved to compel, meaning she asked the court to require defendants to produce, unredacted disciplinary summaries for defendant officers. The motion concerned disciplinary histories that defendants had withheld or produced with redactions. The opinion identifies the plaintiff as asserting claims in a federal civil-rights action, but it does not describe the underlying incident or list the specific claims in detail.
Parties’ positions
Saavedra argued that New York’s repeal of Civil Rights Law § 50-a meant defendants had no basis to withhold unredacted disciplinary histories during discovery. Defendants argued that the repeal did not change the relevance analysis required by Federal Rule of Civil Procedure 26 and maintained that the redacted portions were irrelevant to Saavedra’s claims.
Court’s analysis
The court stated that New York law does not control discoverability and confidentiality in federal civil-rights actions. Instead, Rule 26(b)(1) permits discovery of nonprivileged matter that is relevant to a claim or defense and proportional to the needs of the case.
The court explained that disciplinary records containing allegations wholly unrelated to the allegations in the complaint may be too weakly connected to permit discovery. In federal civil-rights cases alleging excessive force, discovery about prior complaints and officers’ histories is generally limited to complaints similar to the conduct alleged. Applying that principle, the court concluded that Saavedra was not entitled to disciplinary-history portions unrelated to the complaint’s allegations, but was entitled to portions similar to the alleged incident or that raised questions about defendants’ credibility.
Order and disposition
The opinion does not state that the motion to compel was granted or denied. Instead, within one week after the order was filed, defendants were directed to submit to the court for private review the unredacted disciplinary histories they sought to withhold and the redacted copies they had produced to Saavedra. The order directed defendants to send the materials by email to the judge’s chambers. Judge John P. Cronan signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.