Erik Cooper v. Sevier County, Tennessee; Michael R. Hodges, Jr.; Rhett Rutledge; and John Does

Summary

The United States District Court for the Eastern District of Tennessee addresses three motions in Erik Cooper’s pro se 42 U.S.C. § 1983 action concerning alleged failures to provide medical treatment and reasonable accommodations while he was incarcerated in the Sevier County Jail. The court denies Cooper’s motion for reconsideration, grants defendants’ motion to quash subpoenas for depositions of individuals whose information related to other stayed cases, and denies Cooper’s motion to stay the action pending his criminal proceedings. The court also directs Cooper to promptly report any change of address.

Holdings

1. Reconsideration was unwarranted because Cooper identified no intervening change in controlling law, newly available evidence, clear error, or manifest injustice, and his motion improperly repeated prior arguments.
2. The subpoenas were quashed because the proposed depositions sought information irrelevant to any claim or defense in this action and instead concerned Cooper's other stayed cases or the circumstances leading to his incarceration.
3. A stay was unwarranted because Cooper's § 1983 claims were distinct from his ongoing state criminal proceedings and he failed to show that a ruling in this action would substantively affect those proceedings.

Questions Presented

1. Whether Cooper showed a basis under Federal Rule of Civil Procedure 54(b) to reconsider the prior interlocutory protective order.
2. Whether the subpoenas requiring five individuals to appear for depositions should be quashed because the proposed discovery was irrelevant to the claims in this action.
3. Whether this action should be stayed pending resolution of Cooper's ongoing state criminal proceedings.

Disposition

other