Matthew Rigney, et al. v. CSX Transporttation, Inc.

Rigney · United States District Court for the Middle District of Tennessee, Nashville Division · April 14, 2026 · No. 3:22-cv-00342

Summary

The United States District Court for the Middle District of Tennessee overruled CSX Transportation’s objections to a magistrate judge’s Report and Recommendation. The court held that Local Civil Rule 7.01 required CSX to confer with opposing counsel before filing its sanctions-related motion under Federal Rules of Civil Procedure 37 and 41(b). The court adopted the Report and Recommendation and denied CSX’s motion to dismiss.

Holdings

  1. Local Civil Rule 7.01(a)(1) requires the moving party to confer with opposing counsel before filing a motion unless the motion falls within one of the rule's specified exceptions; motions for sanctions under Rules 37 and 41(b) are not excepted.
  2. The court would not entertain CSX's motion because CSX failed to comply with the required meet-and-confer process.

Questions Presented

  1. Whether the district court should adopt the magistrate judge's recommendation to deny CSX's motion under Rules 37(c) and 41(b).
  2. Whether Middle District of Tennessee Local Civil Rule 7.01(a)(1) required CSX to confer with opposing counsel before filing its sanctions motion.
  3. Whether the district court should entertain the sanctions motion despite CSX's failure to comply with the meet-and-confer requirement.

Disposition

other

Cases Cited (2)

  • Allergan, Inc. v. Revance Therapeutics, Inc., No. 3:23-CV-00431, 2025 WL 1487280, at *2 (M.D. Tenn. Mar. 31, 2025)(declined to adopt)
  • HBKY, LLC v. Elk River Exp., LLC, 150 F.4th 480, 488 (6th Cir. 2025)(followed)

Cited In (0)

No citing cases on record yet.

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