L.J., a minor, by and through his next friend and Mother, Cetera Jones; and Cetera Jones, individually v. Memphis-Shelby County Schools; Bryant Parker, School Resource Officer, in his individual capacity; Nekia Patton, in her individual capacity; Rhonda Mitchell, in her individual capacity; and John/Jane Does 1–10

Summary

The United States District Court for the Western District of Tennessee denied Plaintiffs L.J. and Cetera Jones’s motion for expedited discovery before the Rule 26(f) conference. The Court held that Plaintiffs had not shown good cause because the known officer had been identified, the remaining identities could be discovered through ordinary discovery, and the defendant school district was already subject to a duty to preserve electronically stored information.

Holdings

1. A party seeking court-authorized discovery before the Rule 26(f) conference must demonstrate good cause, and good cause requires showing that the requested discovery is necessary for the case to proceed, including when discovery is needed to identify unknown defendants. Plaintiffs did not make that showing because they had already identified the school resource officer and could identify the remaining personnel through ordinary discovery after the Rule 26(f) conference.
2. The possibility that relevant electronically stored information should be preserved did not establish good cause for expedited discovery because the defendant school district was already under a duty to preserve electronically stored information.

Questions Presented

1. Whether Plaintiffs demonstrated good cause for expedited discovery before the Rule 26(f) conference to identify unknown defendants.
2. Whether the need to preserve electronically stored information justified expedited discovery before the Rule 26(f) conference.

Disposition

denied