Steven Harris v. Washington County, Purgatory Correctional Facility, Washington County Sheriff's Office, Kyle Bigelow, Garret McKean, Sgt. Lacie Crowther, Dep. Kevin M. Larson, Dep. Brice Lubitz, Dep. John Jacobs, Dep. Lacey Adams, Dep. Andrew Miller, Dep. Tyler Tait, Dep. Jay B. Chadwick, Dep. Cortney Cheeman, Dep. Bailee W. Mabe, Dep. Kaitlyn Johnson, Warden, and Officer J. Dickerson

Summary

The United States District Court for the District of Utah denied Steven Harris’s motion for sanctions concerning Washington County Defendants’ responses to requests for admission about Utah’s DNA-collection statute and the classification of an offense. The court held that one request sought a pure legal conclusion and that the other was properly denied because the charges had not yet been filed when Harris’s DNA was collected. The court also denied the Defendants’ requests for attorney fees and sanctions because the cited procedural provisions and Rule 11 requirements were not satisfied.

Holdings

1. Federal Rule of Civil Procedure 36 does not require a party to admit or deny a pure matter of law, and a responding party may object when a request calls for a legal conclusion.
2. Sanctions were unwarranted because Defendants were not required to respond to the purely legal first request, and the denial of the second request was accurate on the facts presented.
3. Defendants were not entitled to attorney fees or sanctions because Rule 37(c)(3) does not exist, an award under Rule 37(a)(5)(B) would be unjust, and Defendants failed to comply with Rule 11's procedural requirements.

Questions Presented

1. Whether Defendants' objection and denial to Plaintiff's requests for admission warranted sanctions under Federal Rule of Civil Procedure 37(c)(2).
2. Whether Defendants' request for attorney fees or sanctions under Federal Rule of Civil Procedure 37 or Rule 11 could be granted.

Disposition

other