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Mancia v. Mayflower Textile Services Co.

United States District Court for the District of Maryland · Civil Procedure

Civil ProcedureDiscoveryMotions to CompelRule 26(g)Rule 26(b)(2)(C)Rule 33Rule 34Fed. R. Civ. P. 26(g)

Facts

Plaintiffs served interrogatories and document requests on the defendants seeking contracts, payroll and wage records, hours worked, tax records, business-operation information, and related materials. Defendants Mayflower, Lunil, and Mehta responded to a number of requests with generalized objections such as overbreadth, undue burden, and lack of relevance, and Argo used a similarly non-specific objection to an interrogatory. By the time of the court's review, many disputes had been resolved, but several requests remained contested. The court also observed that, given the modest wage claims and limited number of named plaintiffs, some of plaintiffs' requested discovery might itself be overbroad or disproportionate.

Issue

Whether defendants' generalized discovery objections were sufficient under the Federal Rules, and how the court should address the remaining discovery disputes where the objections appeared waived but the requested discovery might still be disproportionate under Rule 26(b)(2)(C).

Rule

Under Rule 26(g), every discovery request, response, and objection certifies that, after a reasonable inquiry, it is legally warranted, not interposed for an improper purpose, and not unreasonable or unduly burdensome in light of the needs of the case, the amount in controversy, and the importance of the issues. Under Rule 33(b)(4) and Rule 34(b)(2), objections to interrogatories and document requests must be stated with specificity; boilerplate, non-particularized objections are waived absent good cause. Even when objections are waived, Rule 26(b)(2)(C) requires the court sua sponte to limit discovery that is cumulative, obtainable from a less burdensome source, or disproportionate because its burden or expense outweighs its likely benefit.

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

In a wage-and-hour suit in Baltimore, Nora Vega serves an interrogatory on Harbor Stitch Laundry, LLC asking it to identify all supervisors who assigned shifts to the named employees during the relevant year. Harbor Stitch responds only: "Objection, overly broad, unduly burdensome, and irrelevant," and gives no further explanation.

If Nora moves to compel, how should the court most likely rule on the objection?

Explanation. Under the majority opinion, Rule 33(b)(4) requires that grounds for objecting to an interrogatory be stated with specificity. A generic objection such as "overly broad, unduly burdensome, and irrelevant" is a boilerplate objection and is waived absent good cause. The court emphasized that such reflexive objections do not preserve legitimate challenges. (Derived from Mancia v. Mayflower Textile Services Co. (n.d.).)