Court Denies Pro Se Plaintiff’s Motion for Discovery Sanctions in Civil Rights Case
In Boyd v. Etchebehere, et. al., Case No. 13-01966 (E.D. Cal. Mar. 2, 2016), a pro se state prisoner plaintiff sued prison employees for violating his civil rights regarding freedom of religion. During discovery, Plaintiff served a supplemental request for production asking for all documentation regarding the observance of Ramadan at a substance abuse treatment facility. In his request, Plaintiff sought, among other things, a copy of the Administrative Committee Rules regarding inmate activity programs as well as committee meeting documentation. Defendants submitted documents to Plaintiff but Plaintiff asserted that the electronically documents were faded and difficult to read. Plaintiff noted that Defendants used a computer system for storing documents and demanded that Defendants supply the documents from that system in “original form.”
Defendants responded that the documents in question did not exist in their computer system. Plaintiff moved to compel and accused Defendants of spoliation.
The court denied Plaintiff’s motion to compel, finding that Defendants produced what they had and did not respond inappropriately to Plaintiff’s discovery requests. The court also denied Plaintiff’s request for sanctions, concluding that Plaintiff had not demonstrated that Defendant acted with any bad faith and because it found that Defendants had responded sufficiently to all discovery requests.