Reynolds v. Federal Bureau of Prisons

Background

Brian Edwards Reynolds, proceeding without a lawyer, brought an action under Section 1983 against Tara Grove, Alphonso Linley, and Ann Stewart. He alleged inadequate medical care for a medical condition allegedly caused by conditions at the Federal Correctional Institution, Otisville facility. The court was considering Reynolds’s motion to compel, dated May 31, 2022.

Reynolds asked the court to send investigators to the defendants’ workplace and obtain information about a lengthy underground water-pipe replacement or repair project. He also sought affidavits from affected inmates, emails between inmates and staff, emails between staff members, legal correspondence involving inmates and outside entities or attorneys, documents and affidavits from Bureau of Prisons staff, and other communications concerning the alleged medical problem.

Court’s Analysis

The court explained that it is a neutral decision-maker, not an advocate for either side, and does not conduct investigations at a party’s request. Discovery—the process by which parties obtain relevant information from one another—must instead be pursued by serving discovery requests directly on the defendants during the discovery phase. The court also stated that requests must be relevant and are subject to privileges and other protections. It found that Reynolds had not established the relevance of the requested information and appeared to seek documents and communications protected by attorney-client privilege.

The court further held that the request was premature because the parties were still briefing the defendants’ motion to dismiss. In addition, the court’s individual rules and Local Civil Rule 37.2 required a party seeking discovery to request an informal conference before filing such a motion and to meet and confer with the opposing parties. Reynolds had done neither.

Disposition

The court denied Reynolds’s motion to compel and directed the clerk to terminate the motion at ECF No. 61. The opinion also states that the court denied Reynolds’s motion to confer. Requests for documents or communications that were irrelevant to his claims or protected by attorney-client privilege were dismissed with prejudice. All other requests were dismissed without prejudice to renew. Judge Nelson S. Roman also directed the clerk to mail the order to Reynolds and record service on the docket.