Meyer v. County of San Diego

Summary

The United States District Court for the Southern District of California denies William Meyer's motion to compel further discovery responses concerning training materials sought from individual County of San Diego defendants. The court concludes that most of the requested materials are not relevant to qualified immunity because they postdated the alleged constitutional violations, and it rejects arguments that privilege objections were waived. The court also finds that the remaining November 2016 training presentation is protected by attorney-client privilege.

Holdings

1. Training materials created after the alleged constitutional violations were not relevant to the defendants' potential qualified-immunity defense because qualified immunity evaluates whether the law was clearly established at the time of the alleged misconduct.
2. The November 2016 training could potentially be relevant to qualified immunity, but the plaintiff did not establish that the requested materials were discoverable on that basis.
3. The defendants did not waive their privilege or work-product objections through prior disclosure by the County, implied waiver, an allegedly deficient privilege log, or untimely objections.
4. The remaining November 2016 PowerPoint presentation was protected by attorney-client privilege.
5. The withheld training materials, including their native form, were protected by the attorney work-product doctrine.

Questions Presented

1. Whether the requested training materials were relevant and proportional to the claims or to the individual defendants' potential qualified-immunity defense.
2. Whether defendants waived attorney-client privilege or work-product protection by producing similar materials in other litigation, asserting qualified immunity, providing an allegedly deficient privilege log, or making untimely objections.
3. Whether the remaining November 2016 training presentation was protected by attorney-client privilege.
4. Whether the remaining training materials were protected by the attorney work-product doctrine.
5. Whether an in camera review of the withheld materials was necessary.

Disposition

other