Asea, Inc. v. Southern Pac. Transp. Co.

Brief Fact Summary.

Plaintiff sold a transformer to the Los Angeles Department of Water & Power. At some point in the shipment process, the transformer was damaged. Plaintiff brought suit against the railroads. During discovery, the railroads failed to admit or deny eighteen requests. Plaintiff motioned for the court to deem the requests admitted. The district court granted the motion.

Synopsis of Rule of Law.

A district court may order that request for admissions should be admitted when a responding party fails to admit or deny the requests, even though the information is readily available or obtainable to the responding party.

Facts.

Plaintiff, a New York corporation, Asea, Inc. sold electrical transformer to the Los Angeles Department of Water & Power. The transformer was shipped on a ship from the Swedish manufacturer Asea A/B to Los Angeles. After shipment, Southern Pacific Transportation Co. and Harbor Belt Line, Defendants, took custody of the transformer and sent it by railroad to North Hollywood, California. Throughout the shipments, the transformer was damaged. Plaintiff brought suit against the railroads in federal court pursuant to diversity jurisdiction for negligence, breach of warranty, and California statute violations. In this case, the discovery process lasted over a year. Plaintiff served admission request on the railroads, referring to when and how the transformer was damaged. The railroad responded to eighteen requests, indicating that after reasonable review, the railroads could not admit or deny the claims by stating “(n)ot applicable.” Subsequently, Plaintiff concluded that the railroads knew how the transformer was damages. Thus, the railroads should have admitted or denied the statements. Plaintiff motioned to have the court deem the requests admitted. The railroads gave unpersuasive responses at the hearing, and the district court granted Plaintiff’s motion.  

Issue.

Whether a district court may order that request for admissions should be admitted when a responding party fails to admit or deny the requests, even though the information is readily available or obtainable to the responding party.

Held.

Yes, a district court may order that request for admissions should be admitted when a responding party fails to admit or deny the requests, even though the information is readily available or obtainable to the responding party. 

Discussion.

A district court may order that request for admissions should be admitted when a responding party fails to admit or deny the requests, even though the information is readily available or obtainable to the responding party. Failure to respond when the information is readily available or obtainable may result in sanctions. However, if the party is acting in good faith, the party will not be liable. A court, generally, should first seek to have the responding party provide an amended answer. However, district courts have substantial discretion and power to manage discovery. In this case, the district court did not seek an amended answer from the railroad before ordering them to admit the eighteen requests. Nevertheless, the order does not inquire into whether the district court erred in making a reasonable inquiry. Therefore, the judgment is vacated and the district court must review the case to make the necessary findings of reasonableness.