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United Oil Co. v. Parts Associates, Inc.

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

Civil ProcedureDiscoveryRelevanceMotions to CompelWork ProductPrivilege LogFRCP 26(b)(1)FRCP 33(d)

Facts

United Oil paid $820,098.89 to settle product-liability claims brought by Mr. and Mrs. Tiede and then sued Rohm & Haas as manufacturer of certain dyes and Parts Associates as distributor of Fleet-Fill brake cleaner. United Oil's expert opined that xylene and ethyl benzene in the dyes, and perchloroethylene in the brake cleaner, caused Mr. Tiede's liver disease. United Oil sought discovery about prior claims, complaints, lawsuits, persons with knowledge, and materials supporting denials and defenses, including information about other products containing the same allegedly liver-toxic chemicals. Rohm & Haas and Parts objected largely on relevance, overbreadth, work-product, and burdensomeness grounds, while Parts also sought more specific interrogatory answers from United Oil.

Issue

At the discovery stage, when a plaintiff in a failure-to-warn case seeks information about other claims, lawsuits, and products containing the same allegedly injury-causing chemicals, what showing of relevance is required and which party bears the burden? The court also had to decide when requests were too broad, invaded work product, or were inadequately answered by reference to documents.

Rule

Under Rule 26(b)(1), discovery extends to nonprivileged matter relevant to any party's claim or defense, and relevance at the discovery stage is broader than admissibility at trial. A requesting party must make a threshold or apparent showing of relevance by articulating a cogent nexus between the information sought and a claim or defense; once that showing is made, the resisting party bears the burden to demonstrate irrelevance or that marginal relevance is outweighed by harm. In a failure-to-warn case, discovery may include claims, complaints, and lawsuits involving substantially similar products, including other products containing the same alleged injury-causing chemical compounds, when the information bears on notice or causation; but overbroad requests, work-product-demanding requests, and unsupported burdensomeness objections will be denied or limited.

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

In a failure-to-warn suit filed in federal court in Baltimore, Elena Morris alleges that fumes from a coating supplied by Harbor Crest Materials caused her liver damage. She serves discovery on the manufacturer seeking complaints and lawsuits involving the manufacturer's other products that contain the same two solvents her expert identifies as the injury-causing liver toxicants. The manufacturer objects that the other products have different formulas and therefore are irrelevant.

How should the court most likely rule on the relevance objection?

Explanation. Under the majority opinion, Rule 26 relevance at the discovery stage is broad. The requesting party must make a threshold or apparent showing of relevance by articulating a cogent nexus between the information sought and a claim or defense. In a failure-to-warn case, requests concerning other products containing the same alleged injury-causing chemical compounds can satisfy that threshold because they bear on notice and causation. Once that showing is made, the resisting party bears the burden to demonstrate irrelevance or that marginal relevance is outweighed by harm. The court rejected any requirement that the requesting party conclusively prove substantial similarity for trial admissibility before obtaining discovery.