Willie Williams v. Joshua A. Schoenbeck and Jason N. Hart

Summary

The court denied inmate Willie Williams’s motion to compel supplemental discovery responses in his 42 U.S.C. § 1983 due process action concerning prison disciplinary proceedings. The court overruled certain relevance and overbreadth objections but held that defendants were not required to produce documents outside their possession, custody, or control. The court also deferred ruling on an asserted law-enforcement investigatory privilege and required defendants to clarify whether responsive information was being withheld.

Holdings

1. Information concerning persons entering Williams's housing unit, repairs to his cell door, and surveillance of the relevant areas was relevant because it could show that Williams was prevented from attending the disciplinary hearing, identify the officer involved, and bear on whether Defendants knew that his absence was not a refusal.
2. Defendants were not required to obtain or produce responsive documents maintained by the Illinois Department of Corrections when those materials were not within Defendants' possession, custody, or control.
3. Defendants were not required to submit a separate sworn declaration confirming the completeness of their responses to requests for production because counsel's signature on the responses certified their completeness and correctness under Rule 26(g).
4. The court could not resolve Defendants' assertion of the law-enforcement-investigatory privilege on the existing record because Defendants had not specified the information allegedly protected, demonstrated that the privilege applied, or confirmed whether responsive information was being withheld.
5. Defendants did not adequately establish a security objection to production of prison video footage because they asserted the objection only conclusorily; the court nevertheless denied the motion as to the video because Defendants represented that no responsive materials were being withheld and Rule 34 did not require production of materials outside their control.
6. Williams was not entitled to sanctions under Rule 37(a)(5)(B) because his motion to compel was denied.

Questions Presented

1. Whether information concerning persons entering Williams's housing unit, maintenance records, and surveillance video was relevant and sufficiently limited to require further production.
2. Whether Defendants were required to obtain documents maintained by the Illinois Department of Corrections when those documents were not within Defendants' possession, custody, or control.
3. Whether Defendants were required to provide a sworn declaration confirming that their document-production responses were complete.
4. Whether Defendants established the law-enforcement-investigatory privilege as a basis for withholding additional Offender 360 information.
5. Whether Williams was entitled to sanctions under Federal Rule of Civil Procedure 37(a)(5)(B).

Disposition

other