Steven Craycraft, et al. v. Delaware County Sheriff's Department, et al.

Summary

The United States District Court for the Southern District of Indiana denied non-party Judge Thomas A. Cannon’s motion to quash a deposition subpoena. The court held that the subpoena sought factual information about alleged personal bias and relationships, rather than protected judicial deliberative processes, while permitting Cannon to decline questions that cross into privileged deliberations.

Holdings

1. The subpoena was not shown to impose an undue burden warranting quashing because Judge Cannon presented no meaningful argument establishing that the deposition burden outweighed the benefit of the requested testimony.
2. The judicial deliberations privilege did not bar questions directed to Judge Cannon's personal knowledge of alleged relationships, prior dealings, or bias because those factual matters fell outside his protected deliberative judicial functions.

Questions Presented

1. Whether the deposition subpoena should be quashed because it subjected non-party Judge Thomas A. Cannon to an undue burden under Federal Rule of Civil Procedure 45(d)(3)(A)(iv).
2. Whether the judicial deliberations privilege barred deposition questions concerning Judge Cannon's personal knowledge of alleged relationships, prior dealings, or bias involving the plaintiffs and their family.

Disposition

other