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Coalition of Black Leadership v. Doorley

United States District Court for the District of Rhode Island · Civil Procedure

Civil ProcedureDiscoveryEvidenceRule 34Rule 37Rule 43(a)photographsdiscovery sanctions

Facts

Three women connected to the plaintiff side alleged that during their July 16, 1970 arrests they were threatened, assaulted, beaten, kicked, subjected to excessive force, harassed, and denied contact with counsel or family. The charges against them were later dismissed in Rhode Island District Court on the City's motion. Defendants attempted to introduce police photographs taken the night of the arrests, which were reasonably expected to show the women unmarked and unbruised. Plaintiffs had previously requested production of case records and related documents concerning two of the arrests, and defendants produced the files but not the attached photographs.

Issue

Whether the federal court should exclude the police photographs from evidence because defendants failed to produce them in discovery and because Rhode Island law gave the women a right to destruction of the photographs after dismissal of the charges. Also, whether the court had authority in this civil case to suppress evidence allegedly held in violation of state law.

Rule

Photographs are included within Rule 34's term "documents," so failure to produce requested arrest photographs may justify exclusion under Rule 37. Where a state statute mandatorily grants a person whose charges have been dismissed and against whom no charges are outstanding a right to destruction of arrest photographs, a federal court may treat the photographs as if they should already have been destroyed and exclude them from evidence in a civil case; Rule 43(a) gives the court competence to decide such state-law evidentiary questions.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal civil rights suit in Boston, Talia Moreno alleges city officers used excessive force during her arrest. During discovery, her counsel requests "all arrest records, incident reports, memoranda, and other related documents" concerning the arrest; the city produces the file but omits booking photographs clipped inside it, then offers the photos at trial to show she appeared uninjured.

How should the federal court most likely rule on the photographs?

Explanation. The majority treated photographs as expressly included within Rule 34's "documents." Where requested arrest files and related documents encompassed attached photographs, failure to produce them was sufficient to warrant exclusion under Rule 37. The opinion did not require a separate, photo-specific request, a showing of bad faith, or limit relief to monetary sanctions.