Erica Dandry Constanza, et al. v. Sparta Insurance Company, et al.

Summary

The United States District Court for the Eastern District of Louisiana granted Huntington Ingalls Incorporated’s motion requiring plaintiffs to disclose the identities of all parties with whom they had settled. The court held that disclosure of settlement identities was appropriate to facilitate potential virile-share credits and reduce jury confusion, while the settlement amounts and contents remained subject to evidentiary limitations under Federal Rule of Evidence 408.

Holdings

1. Plaintiffs must immediately disclose to defendants the identities of all parties with whom they entered into settlements from the inception of the action through the conclusion of trial.
2. Rule 408 did not preclude an order requiring disclosure of the identities of settling parties because the motion did not seek to introduce settlement evidence to prove or disprove the validity or amount of the claim.

Questions Presented

1. Whether the court should require plaintiffs to disclose the identities of all parties with whom they had entered into settlements in the action.
2. Whether Federal Rule of Evidence 408 barred the requested disclosure of the existence and identities of settlements.

Disposition

other