Robbins v. Candy Digital, Inc.

Background

Defendants Candy Digital Inc., Fanatics, LLC, Fanatics Holdings, Inc., Scott Lawin, and Anthony Fitzgerald moved to stay discovery while their respective motions to dismiss were pending. A discovery stay would have paused the exchange of information and documents while the court considered whether the complaint adequately stated claims.

The underlying dispute includes claims under the Family and Medical Leave Act of 1993. The Candy Digital Defendants argued that Robbins was not eligible for the leave when he requested it and that the complaint therefore did not adequately plead unlawful interference and retaliation. The Fanatics Defendants argued that Robbins had not sufficiently alleged that they were his employers or that a joint-employer relationship existed. Robbins argued, among other things, that a document relied on by the Candy Digital Defendants could not properly be considered on a motion to dismiss, that the court should not convert the motions into motions for summary judgment at the beginning of the case, and that he had adequately alleged his claims.

Standard for a Discovery Stay

The court explained that a motion to dismiss does not ordinarily stay discovery, except in cases covered by the Private Securities Litigation Reform Act. A court may stay discovery for good cause. In evaluating that request, courts consider the breadth of the discovery, any resulting prejudice, and the strength of the motion to dismiss.

Court’s Analysis

The court found that the strength of the defendants’ dismissal arguments did not justify a stay. It described the arguments on both sides as strong and concluded that the defendants had not shown substantial grounds for dismissal or a strong likelihood of success.

The court also found that the scope of discovery did not justify a stay. The Fanatics Defendants had not attached Robbins’s discovery requests and relied on the number of subjects and individuals involved. The Candy Digital Defendants identified 35 people with potentially discoverable information, 34 document requests, and 7 interrogatories. The court concluded that this discovery was not exceptional, that listing 35 people did not mean all would be deposed, and that the requests covered a relatively short period—from November 1, 2021, to the present.

The court stated that objections to allegedly overbroad requests or interrogatories should first be raised in discovery responses and through a meet-and-confer process. If the parties could not resolve those issues, the defendants could seek a protective order.

Although Robbins did not identify specific prejudice from a stay, the court said that the absence of prejudice alone did not support pausing discovery. The court therefore considered the defendants’ other arguments insufficient.

Disposition

The court DENIED the defendants’ motions to stay discovery and directed the clerk to close Dkt. Nos. 61 and 63. This order did not decide the motions to dismiss or the merits of Robbins’s Family and Medical Leave Act claims.

Classification

This is a procedural order because it resolves discovery-management motions without deciding the underlying claims or the motions to dismiss.