Summary
The United States District Court for the Middle District of Pennsylvania resolves Antonio Hawley’s motion to compel discovery in a prisoner civil-rights action. The court denies the motion except that defendants must submit for in camera review any PREA documentation showing misconduct findings involving the named defendants, or confirm that no such records exist. The court also addresses requests for camera footage, prison security policies, grievance-related staff information, and other inmates’ PREA complaints.
Holdings
- A discovery request that merely restates the legal scope of discovery does not require a further factual response.
- The court will not compel production of documents or evidence that the responding party establishes do not exist, although the responding party remains subject to its duty to supplement discovery.
- The court will not compel wholesale production of confidential prison security policies where institutional-security concerns outweigh the inmate's asserted need for the manuals.
- Broad, generalized requests for all PREA complaints involving defendants or for the names, titles, and duties of all staff involved in inmate grievances are not sufficiently limited to warrant compelled production.
- Potentially relevant PREA documentation concerning findings of misconduct by named defendants must be submitted to the court for in camera review; if no responsive records exist, defendants must notify the court.
Questions Presented
- Whether Hawley was entitled to an order compelling responses to discovery requests that merely restated Rule 26's discovery standard.
- Whether the court could compel production of camera footage that defendants reported no longer existed.
- Whether prison security policies, including DOC Policy 6.5.1, were discoverable despite confidentiality and institutional-security concerns.
- Whether broad requests for PREA complaints involving named defendants and information about all grievance-related staff should be compelled.
- Whether narrowly tailored PREA records concerning findings of misconduct by named defendants should be submitted to the court for in camera review.
Disposition
other
Cases Cited (23)
- Marroquin-Manriquez v. I.N.S., 699 F.2d 129, 134 (3d Cir. 1983)(followed)
- Farmers & Merchants National Bank v. San Clemente Financial Group Securities, Inc., 174 F.R.D. 572, 585 (D.N.J. 1997)(followed)
- Saldi v. Paul Revere Life Insurance Co., 224 F.R.D. 169, 174 (E.D. Pa. 2004)(followed)
- Scott Paper Co. v. United States, 943 F. Supp. 501, 502 (E.D. Pa. 1996)(followed)
- Kresefky v. Panasonic Communications and Systems Co., 169 F.R.D. 54, 64 (D.N.J. 1996)(followed)
- Hasbrouck v. BankAmerica Housing Services, 190 F.R.D. 42, 44-45 (N.D.N.Y. 1999)(followed)
- EEOC v. Mr. Gold, Inc., 223 F.R.D. 100, 102 (E.D.N.Y. 2004)(followed)
- Halsey v. Pfeiffer, No. 09-1138, 2010 WL 2735702, at *1 (D.N.J. Sept. 27, 2010)(followed)
- Robinson v. Folino, No. 14-227, 2016 WL 4678340, at *2(followed)
- Jackson v. Beard, No. 11-1431, 2014 WL 3868228, at *5 (M.D. Pa. Aug. 6, 2014)(followed)
Showing top 10 of 23.
Cited In (0)
No citing cases on record yet.
Court Document
Open PDFLoading document…