## Facts

- A federal diversity wrongful-death/products-liability action in North Carolina alleged a design defect in a Jeep manufactured by American Motors Corporation (AMC).
- Richard G. Snyder, a University of Michigan Highway Safety Research Institute researcher, participated in an adverse safety study of utility vehicles prepared for the Insurance Institute for Highway Safety.
- Snyder was not a party to the North Carolina litigation, was not retained by either side as an expert, and was not court-appointed.
- AMC issued a subpoena from the Eastern District of Michigan requiring Snyder to appear for deposition in Ann Arbor and to produce expansive categories of research materials related to the study (including “any and all” data, notes, correspondence, and media).
- Snyder moved to quash the subpoena in the Eastern District of Michigan.
- The district court granted the motion and quashed the subpoena; AMC appealed.

## Issues

1. Whether the district court abused its discretion by quashing a subpoena seeking extensive deposition and document discovery from a non-party academic researcher who was not a retained or court-appointed expert.
2. What limits a court may impose on discovery directed to non-party experts when the request is broad and burdensome and the relevant work is already published.

## Decision

- The Sixth Circuit affirmed the order quashing the subpoena.
- The court held the district court acted within its discretion in refusing the requested discovery from a non-party researcher uninvolved in the litigation as an expert.
- The breadth and intrusiveness of AMC’s demands supported quashing, particularly given the availability of the study in published form.
- Appellate review was limited to abuse of discretion; none was shown.

## Legal Principles

- Trial courts have broad discretion to quash or limit subpoenas directed to non-party experts who are strangers to the litigation.
- Discovery sought from an unretained, non-party expert may be curtailed when it imposes undue burden or resembles harassment, especially when it would intrude on the expert’s research work and internal materials.
- The availability of the expert’s conclusions through published materials weighs against compelling deposition and production of underlying files.
- Non-party expert discovery is treated differently from ordinary party discovery; courts may require a stronger showing of need before compelling compliance.

## Conclusion

The Sixth Circuit upheld the district court’s decision to protect a non-party academic researcher from sweeping subpoena demands, emphasizing the trial court’s discretion to prevent undue burden and unnecessary intrusion where the researcher was not engaged as an expert in the case and the relevant work was publicly available.


Buchanan v. Am. Motors Corp., 697 F.2d 151 (6th Cir. 1983)