A.M. by and through next friend, Nakala Murry, and Nakala Murry v. City of Indianola, Mississippi and Officer Greg Capers

Summary

The United States District Court for the Northern District of Mississippi denied Plaintiffs’ Motion to Compel. The court held that discovery remained stayed due to pending immunity-based motions and that the requested broad electronic-discovery search exceeded the limited Rule 56(d) discovery previously authorized. The court declined to compel department-wide searches, additional discovery concerning an attorney, sanctions, or fee-shifting.

Holdings

1. The Court may not compel broad merits discovery that substantially exceeds the limited Rule 56(d) discovery authorized while immunity-based motions remain pending and the discovery stay remains in effect.
2. The Court's prior Rule 56(d) orders and the parties' post-deposition discussions did not waive the immunity-based discovery stay or authorize unlimited future electronic discovery.
3. The Court would not compel additional discovery concerning Attorney V. Dorsey based on speculation about the nature and extent of her involvement.
4. Sanctions and fee-shifting were unwarranted on the present record.

Questions Presented

1. Whether Plaintiffs were entitled to compel broad supplemental electronic discovery while discovery remained stayed under Local Uniform Civil Rule 16(b)(3)(B) because immunity-based motions were pending.
2. Whether the Court's prior Rule 56(d) orders or the parties' supplementation discussions authorized the department-wide searches and additional discovery requested by Plaintiffs.
3. Whether the single email produced by MBI warranted compelled discovery concerning Attorney V. Dorsey.
4. Whether sanctions or fee-shifting should be imposed.

Disposition

other