Matthew Wright v. State of Washington, et al.

Summary

The United States District Court for the Western District of Washington partially granted Matthew Wright’s motion for leave to serve additional interrogatories in his 42 U.S.C. § 1983 action concerning his transfer from Monroe Corrections Center and exclusion from returning there. The court authorized up to ten additional interrogatories and five additional requests for production, finding a limited expansion appropriate despite Wright’s failure to provide proposed interrogatories or a particularized justification for doubling the standard limit.

Holdings

1. A party seeking leave to serve additional interrogatories must make a persuasive, particularized showing that exceeding the numerical limit is necessary and consistent with Rule 26's proportionality and burden limits. Wright failed to make that showing for the requested twenty-five additional interrogatories because he did not provide proposed interrogatories or a specific justification for doubling the limit.
2. The court may grant a limited expansion of written discovery when the issues are important and relevant information is largely in the opposing party's exclusive possession, even though the movant has not justified the full amount requested. Wright was permitted to serve up to ten additional interrogatories and five additional requests for production.

Questions Presented

1. Whether Wright showed that he should be permitted to serve twenty-five additional interrogatories beyond the twenty-five-interrogatory limit in Federal Rule of Civil Procedure 33(a)(1).
2. Whether the court should permit a limited expansion of written discovery because information concerning the alleged First Amendment retaliation and internal Department of Corrections decision-making was largely in defendants' exclusive possession.

Disposition

other