Landreth v. Lehil

Summary

This order addresses a pro se prisoner’s motions concerning discovery in a 42 U.S.C. § 1983 action involving the prescribing of transition or tinted eyeglass lenses. The court denies sanctions and further responses concerning several discovery requests directed to Defendant Posson, while granting in part and denying in part requests for additional discovery and related relief concerning Defendants Carrick and Posson. The court applies Federal Rules of Civil Procedure 26, 36, and 37 and discusses the scope of discovery, sufficiency of responses, and document control.

Holdings

1. A party has fully responded to an interrogatory when the response explains the requested criteria or medical-necessity determination; a disagreement with the substance or truth of the response does not justify compelling a further response.
2. A specific denial satisfies Federal Rule of Civil Procedure 36 when the responding party does not admit the matter; the court will not determine the truth or accuracy of the denial on a motion to compel.
3. Discovery sanctions were unwarranted because Defendant Posson complied with the court's prior order and provided sufficient supplemental responses.
4. A party responding to a document request must conduct a reasonable and diligent inquiry and must produce responsive documents within its possession, custody, or control, including documents over which it has constructive control; if no documents exist, the party must state that fact with sufficient specificity.
5. A response stating only that clarification was unnecessary does not fully answer an interrogatory asking what efforts were made to clarify expectations; the responding party must provide a further response addressing the efforts made.
6. The remaining requests for further responses, additional discovery, an extension of discovery deadlines, and in-camera review were denied because responses had been served, the requested relief was unnecessary or unsupported, or the documents were not responsive or had not been shown to exist.

Questions Presented

1. Whether Defendant Posson was required to provide additional answers to interrogatories concerning criteria for transition lenses, tinted lenses, communications with Dr. Ottenbacher, and a request for admission concerning ultraviolet-light exposure.
2. Whether Plaintiff was entitled to sanctions based on Defendant Posson's discovery responses.
3. Whether Defendant Carrick was required to supplement his response to a request for production seeking documents from a 2015 Durable Medical Equipment Committee meeting.
4. Whether Defendant Carrick was required to supplement his response to an interrogatory concerning efforts to clarify expectations under a 2015 memorandum.
5. Whether Plaintiff was entitled to additional discovery, an extension of discovery deadlines, or an in-camera review of allegedly privileged documents.

Disposition

other