## Facts

- Bhupendra and Gunvanti Chudasama bought a used 1989 Mazda MPV minivan in Georgia.
- An accident occurred when Bhupendra lost control and hit a utility pole; Gunvanti suffered serious injuries and the vehicle was totaled.
- The Chudasamas sued Mazda Motor Corporation and Mazda Motor of America in federal court, alleging product defects (including brakes and side structure) and a fraud claim based on marketing representations.
- Mazda moved to dismiss the fraud count for failure to plead with particularity under Federal Rule of Civil Procedure 9(b), but the district court did not rule on the motion.
- Discovery became expansive and contentious: plaintiffs served sweeping, often vague requests; Mazda objected broadly and produced little, leading to repeated disputes.
- The district court signaled reluctance to resolve discovery disputes and threatened sanctions if forced to rule.
- The district court ultimately compelled discovery, struck all of Mazda’s pleadings, entered default judgment as a sanction under Rules 26 and 37, ordered fees and costs, and vacated a protective order covering confidential business information.
- Mazda appealed the sanctions and default judgment.

## Issues

1. Whether the district court abused its discretion by allowing broad discovery to proceed without ruling on a potentially dispositive or narrowing motion to dismiss the fraud claim.
2. Whether the district court abused its discretion by imposing case-dispositive sanctions—striking pleadings and entering default judgment—under Rules 26 and 37 in the context of overbroad requests, asserted objections, and inadequate judicial management.

## Decision

- The Eleventh Circuit held the district court abused its discretion in its handling of the case and discovery.
- The court vacated the orders striking Mazda’s pleadings, entering default judgment, awarding fees and costs, and related sanction rulings.
- The court remanded with instructions that the case be reassigned to a different district judge.

## Legal Principles

- District courts must actively manage discovery and rule on pending pretrial motions and discovery objections, particularly when the disputes will not otherwise be resolved.
- When a claim is weak and materially expands discovery, the court should address threshold motions (such as Rule 9(b) challenges) before permitting discovery to mushroom.
- Case-dispositive discovery sanctions (including default judgment) are a last resort and generally require a clear record supporting such relief and consideration of lesser sanctions.
- Sanctions analysis must account for legitimate objections to vague, burdensome, or overbroad requests; parties should not be effectively forced into “self-help” by judicial nonintervention.
- Protective-order practice must be handled evenhandedly; seeking protection for confidential information should not be treated as sanctionable conduct.

## Conclusion

The Eleventh Circuit vacated a default judgment entered as a discovery sanction because the district court failed to control discovery, failed to decide a key motion that could have limited the case, and imposed extreme sanctions without a sound basis or adequate consideration of lesser measures; the matter was remanded for reassignment and further proceedings.


Chudasama v. Mazda Motor Corp., 123 F.3d 1353 (11th Cir. 1997)