2002 WL 1759828 (N.D. Ill. 2002)
Facts & Procedural History
Plaintiffs were black and Latino employees who worked at one of the defendant’s plants and alleged they were exposed to a hostile work environment, such as being subjected to racially insulting and derogatory comments by defendant’s management-level employees. After bringing an action under Title VII of the Civil Rights Act, plaintiffs filed a motion to compel discovery. The motion sought other race and national origin discrimination complaints made against the defendant by other employees who worked at the same plant.
Was plaintiff’s discovery request for other race and national origin discrimination complaints filed by employees who worked at the same plant overbroad?
Holding / Rule
No. Motion granted. Federal Rule of Civil Procedure 26(b)(1) permits discovery into “any non-privileged matter that is relevant to any party’s claim or defense.” Discoverable information does not need to be admissible at trial and is relevant under Rule 26 if it “appears reasonably calculated to lead to the discovery of admissible evidence.” However, a court can limit discovery if it determines, among other things, that ti is unreasonably cumulative or duplicative, obtainable from another source that is more convenient, less burdensome, or less expensive, or the burden or expense of the proposed discovery outweighs its likely benefit.
The plaintiffs’ discovery request was narrowly tailored to their specific claims—it only sought other discrimination complaints from the previous four years which alleged the same types of discrimination and which were made by employees who worked at the same plant. The other complaints may be relevant to establishing defendant’s pretext for discrimination. Plaintiffs did not seek discovery relating to all alleged discriminatory practices by defendant, which likely would have been overbroad.