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Wright v. City of Philadelphia

United States District Court, E.D. Pennsylvania

April 28, 2017

ANTHONY WRIGHT, Plaintiff,
v.
CITY OF PHILADELPHIA, Defendants.

          MEMORANDUM

          GENE E.K. PRATTER United States District Judge

         I. Introduction

         Mr. Wright sued the City of Philadelphia and a number of its former police department employees for constitutional violations arising out of his 1991 arrest, 1993 prosecution, and 25-year imprisonment for a rape and murder he did not commit. In 2016 a jury acquitted Mr. Wright of the rape and murder after a retrial which included DNA evidence not available at his initial trial.[1] In connection with his Monell claim against the City of Philadelphia, Mr. Wright seeks production of documents from the City for the period 1995 to 2016 related to: the (i) investigations of homicides; (ii) operation of the Homicide Unit; (iii) interrogation of suspects; (iv) interrogation of witnesses; (v) detention of witnesses; (vi) fabricating, tampering, and/or mishandling of evidence; (vii) planting of evidence; (viii) duty to properly investigate; (ix) duty to disclose exculpatory evidence; and (x) failure to consider exculpatory evidence.[2]

         For the reasons that follow, the Court will grant in part and deny in part Mr. Wright's Motion to Compel.

         II. Legal Standard

         Federal Rule of Civil Procedure 26(b)(1) sets forth the scope of discovery in a civil action:

Parties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit. Information within this scope of discovery need not be admissible in evidence to be discoverable.

Fed. R. Civ. P. 26(b)(1).

         A party who has not received complete discovery can move for a court order compelling production. Fed.R.Civ.P. 37(a). The moving party bears the initial burden to prove that the requested discovery falls within the scope of discovery as defined by Rule 26(b)(1). Williams v. CVS Caremark Corp., No. 15-5773, 2016 WL 4409190, at *4 (E.D. Pa. Aug. 18, 2016). If the moving party meets this initial burden, the burden then shifts to the opposing party to demonstrate that the requested discovery (i) does not fall within the scope of discovery contemplated by Rule 26(b)(1), or (ii) is not sufficiently relevant to justify the burden of producing the information. Id. (citation omitted).

         III. Discussion

         The City argues that the time period for which the documents are sought, from 1995 to 2016, is excessive because Mr. Wright's arrest occurred in 1991, his initial trial was in 1993, and his retrial happened in 2016. Accordingly, the City maintains that only three years are relevant to Mr. Wright's allegations: 1991, 1993, and 2016. Mr. Wright argues that the entire 25-year time period-from Mr. Wright's arrest in 1991 to his retrial in 2016-is relevant because throughout this entire time period the City failed to take appropriate actions to address the alleged unconstitutional conduct, all to the disadvantage of Mr. Wright who continued to languish in jail or under the shadow of prosecution.

         The information Mr. Wright seeks can be roughly separated into two buckets. First are materials implicating Mr. Wright's allegations both in connection with his initial arrest and prosecution as well as his retrial. Falling into this bucket is information related to the City's policies, customs, and training materials with regard to the (i) fabricating, tampering, and/or mishandling of evidence; (ii) duty to disclose exculpatory evidence; and (iii) failure to consider exculpatory evidence. Second are materials only implicating Mr. Wright's allegations concerning the initial investigation of Mr. Wright in 1991. Falling into this bucket is information related to the City's policies, customs, and training materials with regard to the (i) investigations of homicides; (ii) operation of the Homicide Unit; (iii) interrogation of suspects; (iv) interrogation of witnesses; (v) detention of witnesses; (vi) planting of evidence; and (vii) duty to properly investigate. Mr. Wright is entitled to Monell discovery into the first bucket of information implicating his 2016 retrial; he is not entitled to Monell materials as to the second bucket of information implicating only the 1991 investigation of Mr. Wright.

         A. Materials Related to the 2016 Retrial

         This case presents an atypical timeline with respect to Mr. Wright's Monell claim against the City. Mr. Wright alleges that the City's policies, customs, procedures, and failure to adequately train and/or discipline its employees resulted in the violations of his constitutional rights during two distinct time periods-his initial arrest/prosecution and his retrial. To ultimately succeed on his Monell claim, Mr. Wright will have to demonstrate that the City was deliberately indifferent to the ...


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