Thompson v. Department of Housing and Urban Devel.

Brief Fact Summary.

African American residents in Baltimore public housing developments filed suit against the U.S. Department of Housing and Urban Devel. (HUD), claiming that HUD segregating the housing developments since 1993.

Synopsis of Rule of Law.

A federal district court is permitted to employ a cost-benefit analysis during discovery that determines whether the request is unduly burdensome, expensive, or overbroad.

Facts.

African American residents in Baltimore public housing developments filed suit against the U.S. Department of Housing and Urban Devel. (HUD), claiming that HUD segregating the housing developments since 1993. When the plaintiffs made discovery requests, the defendants objected claiming that the requests were overbroad, burdensome, and exceeded the scope of discovery.

Issue.

Whether a federal district court is permitted to employ a cost-benefit analysis during discovery that determines whether the request is unduly burdensome, expensive, or overbroad?

Held.

Yes. The motion to compel production is denied without prejudice. The parties are ordered to meet and resolve their disputes. Plaintiffs sought discovery of 75 years worth of material and have not indicated how it relates to the discovery process. The defendants have claimed that the request are overbroad and burdensome, but have not provided evidence of the cost-benefits analysis.

Discussion.

A federal district court is permitted to employ a cost-benefit analysis during discovery that determines whether the request is unduly burdensome, expensive, or overbroad. The cost-benefits analysis includes factors such as: (1) the burden and expense associated with production, (2) benefits of discovery, (3) needs of the suit, (4) amount at stake, (5) the resources of the parties, (6) the importance of the case, (7) whether discovery is likely to resolve issues.