United States District Court, M.D. Pennsylvania
C. Carlson United States Magistrate Judge
Statement of Facts and of the Case
vehicular accident case comes before us for resolution of a
discovery dispute and motion to compel. (Doc. 31). The
plaintiff, HSI, has propounded a series of interrogatories
upon the defendant aimed in part at identifying any
technology in the defendant's truck which would have
recorded events at the time of this accident, including such
matters as the truck's speed and whether brakes were
applied prior to the collision. The defendant's response
to these interrogatories simply refers the plaintiff
generally to the deposition testimony of several witnesses
without adding further detail responsive to the specific
interrogatories. Deeming this response inadequate, HSI has
moved to compel more fulsome responses to these
interrogatories. (Doc. 31). This motion is fully briefed by
the parties and is, therefore, ripe for resolution. (Docs.
reasons set forth below, the motion will be GRANTED.
basic guiding principles inform our resolution of the instant
discovery dispute. At the outset, Rule 37 of the Federal
Rules of Civil Procedure governs motions to compel discovery,
and provides that:
(a) Motion for an Order Compelling Disclosure or Discovery
(1) In General. On notice to other parties and all affected
persons, a party may move for an order compelling disclosure
or discovery. . . .
Fed. R. Civ. P. 37(a).
scope of what type of discovery may be compelled under Rule
37 is defined, in turn, by Rule 26(b)(1) of the Federal Rules
of Civil Procedure, which provides that:
Unless otherwise limited by court order, the scope of
discovery is as follows: 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
Fed. R. Civ. P. 26(b)(1).
regarding the proper scope of discovery, and the extent to
which discovery may be compelled, are matters consigned to
the court's discretion and judgment. Thus, it has long
been held that decisions regarding Rule 37 motions are
“committed to the sound discretion of the district
court.” DiGregorio v. First Rediscount Corp.,
506 F.2d 781, 788 (3d Cir. 1974). Similarly, issues relating
to the scope of discovery permitted under Rule 26 also rest
in the sound discretion of the Court. Wisniewski v.
Johns-Manville Corp., 812 F.2d 81, 90 (3d Cir. 1987).
Therefore, a court's decisions regarding the conduct of
discovery, will be disturbed only upon a showing of an abuse
of discretion. Marroquin-Manriquez v. I.N.S., 699
F.2d 129, 134 (3d Cir. 1983). Likewise, discovery sanction
decisions rest in the sound discretion of the court.
Grider v. Keystone Health Plan Cent., Inc., 580 F.3d
119, 134 (3d Cir. 2009). This far-reaching discretion extends
to rulings by United States Magistrate Judges on discovery
matters. In this regard:
District courts provide magistrate judges with particularly
broad discretion in resolving discovery disputes. See
Farmers & Merchs. Nat'l Bank v. San Clemente Fin.
Group Sec., Inc., 174 F.R.D. 572, 585 (D.N.J. 1997).
When a magistrate judge's decision involves a
discretionary [discovery] matter . . ., “courts in this
district have determined that the clearly erroneous standard
implicitly becomes an abuse of discretion standard.”
Saldi v. Paul Revere Life Ins. Co., 224 F.R.D. 169,
174 (E.D. Pa. 2004) (citing Scott Paper Co. v. United
States, 943 F.Supp. 501, 502 (E.D. Pa. 1996)). Under
that standard, a magistrate judge's discovery ruling
“is entitled to great deference and is reversible only
for abuse of discretion.” Kresefky v. Panasonic
Commc'ns and Sys. Co., 169 F.R.D. 54, 64 (D.N.J.
1996); see also Hasbrouck v. BankAmerica Hous.
Servs., 190 F.R.D. 42, 44-45 (N.D.N.Y. 1999) (holding
that discovery rulings are reviewed under abuse of discretion
standard rather ...