Costco Wholesale Corp. v. Carl Ditmars

Summary

The Florida Third District Court of Appeal granted Costco Wholesale Corp.'s petition for writ of certiorari and quashed a discovery order requiring production of all Costco policies and procedures, including materials expressly deemed irrelevant to the negligence action. The court held that trial courts may not authorize carte blanche discovery of irrelevant or confidential materials as a sanction for discovery violations.

Holdings

1. Certiorari relief was appropriate because the order departed from the essential requirements of law by authorizing carte blanche discovery of irrelevant materials and caused irreparable harm that could not be remedied on appeal.
2. A trial court may not grant discovery of otherwise irrelevant or confidential materials as a sanction for discovery violations.
3. The order was impermissibly overbroad because it required production of all Costco policies and procedures, including documents unrelated to the negligence claims concerning store-shelf organization, employee training, or accident-avoidance procedures.

Questions Presented

1. Whether the circuit court's discovery order permitting production of all Costco policies and procedures, including materials irrelevant to the negligence claims, departed from the essential requirements of law.
2. Whether a trial court may compel production of otherwise irrelevant or confidential materials as a sanction for discovery violations.
3. Whether the challenged discovery order caused irreparable harm warranting certiorari relief.

Disposition

quashed