Adrian Moreno v. Unique Plumbing LLC, a Utah LLC; Steven Nielsen, an individual; and Does 1 to 100, inclusive

Summary

The court granted Plaintiff Adrian Moreno’s motion to compel discovery concerning Unique Plumbing LLC’s financial condition in connection with his claims for punitive damages under Title VII and 42 U.S.C. § 1981. The court held that Plaintiff was not required to establish a prima facie case for punitive damages before obtaining relevant pretrial financial discovery, particularly because the information was subject to a protective order. The court denied Plaintiff’s request for attorney fees and costs because Defendant’s opposition was substantially justified given the divergent authority on the issue.

Holdings

1. A plaintiff asserting punitive-damages claims need not establish a prima facie case for punitive damages before obtaining pretrial discovery of the defendant's financial records.
2. The requested financial records were relevant to Plaintiff's punitive-damages claims, and Defendant's overbreadth and undue-burden objections did not justify refusing production.
3. Plaintiff was not entitled to attorney fees and costs under Rule 37(a)(5) because Defendant's opposition was substantially justified in light of the divergent authority concerning the timing and requirements for financial discovery.

Questions Presented

1. Whether a plaintiff asserting punitive-damages claims must establish a prima facie case for punitive damages before obtaining pretrial discovery of the defendant's financial records.
2. Whether the requested 2024 and 2025 financial records were relevant and proportional under Federal Rule of Civil Procedure 26(b)(1), and whether Defendant's overbreadth and undue-burden objections justified withholding them.
3. Whether Plaintiff was entitled to attorney fees and costs for bringing the discovery motion under Federal Rule of Civil Procedure 37(a)(5).

Disposition

other