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

Brief Fact Summary.

Southern Pac. Transp. Co. failed to admit or deny what happened to a transformer manufactured by Asea, Inc. that was damaged in transit to Los Angeles, California.

Synopsis of Rule of Law.

Under FRCP 36(a), A district court can order a request for admissions to be admitted if the responding party failed to admit or deny the claims despite the information being known after reasonable inquiry.

Facts.

A transformer manufactured by Asea was shipped to Los Angeles, California by by rail through Southern Pac. Transp. Co. (Southern). The transformer was damaged and Asea sought admissions relating to how and when the transformer was damaged. Southern neither admitted or denied to the admissions requests and Asea claimed that Southern knew what happened to the transformer. Asea moved to have the claims admitted and Asea’s request was granted.

Issue.

Whether a district court can order a request for admissions to be admitted if the responding party failed to admit or deny the claims despite the information being known after reasonable inquiry?

Held.

Yes. The judgment is vacated and remanded. The court did not determine whether the railroads failed to make a reasonable inquiry or had sufficient information to admit or deny the matters before ordering the matter admitted.

Discussion.

Under FRCP 36, a party cannot refuse to admit or deny claims based on insufficient information unless he lacks sufficient information to admit or deny after making a reasonable inquiry. Failure to make a reasonable inquiry may result in sanctions.