Facts
- African-American residents of Baltimore public housing sued HUD and local housing and city officials, alleging decades of intentional racial segregation in public housing.
- The class action was filed in January 1995 and asserted constitutional and federal civil-rights claims, including Title VI and the Fair Housing Act.
- In 1996, the parties entered a partial consent decree resolving certain claims and aspects of relief.
- In mid-2000, plaintiffs served extensive interrogatories and document requests on local defendants seeking information and documents dating back to 1933 on a wide range of housing policies and practices.
- Local defendants objected that the requests were overbroad and unduly burdensome, particularly under the December 1, 2000 amendments narrowing Federal Rule of Civil Procedure 26(b)(1).
- Plaintiffs moved to compel responses from the local defendants; the ruling addressed only the discovery dispute, not the merits.
Issues
- Under amended Rule 26(b)(1), when may a court authorize discovery beyond matters relevant to a party’s claims or defenses to broader “subject matter” discovery upon a showing of good cause?
- Under Rules 26(b)(2) and 26(c), whether plaintiffs’ broad, decades-spanning requests should be limited or denied because the burden and expense outweigh the likely benefit.
Decision
- The court denied the motion to compel without prejudice.
- The court held that amended Rule 26 makes “claim or defense” relevance the default scope and requires a good-cause showing for broader “subject matter” discovery.
- Applying proportionality, the court found plaintiffs had not justified the sweeping breadth and burden of the requested historical discovery on the record presented.
- The court left plaintiffs free to renew the motion with narrower, better-supported requests tied to specific claims or defenses.
Legal Principles
- Under Rule 26(b)(1), discovery is limited to nonprivileged matter relevant to any party’s claim or defense; broader “subject matter” discovery requires court approval and good cause.
- The “reasonably calculated to lead to the discovery of admissible evidence” concept does not expand discovery beyond the limits of Rule 26(b)(1).
- Under Rule 26(b)(2), the court must limit discovery that is unreasonably cumulative or duplicative, where the requesting party has had ample opportunity, or where burden or expense outweighs likely benefit, considering case needs, resources, issues’ importance, and the discovery’s importance to resolution.
- The court may limit discovery on its own initiative under Rules 26(b)(2) and 26(c), not only on motion by the responding party.
Conclusion
The court applied the amended Rule 26 framework to deny a motion to compel sweeping, long-range discovery, holding that parties must connect requests to specific claims or defenses and satisfy proportionality, while allowing renewed, narrowed requests upon an adequate showing.