Cerrato v. Nutribullet, LLC

Citation. 2017 U.S. Dist. LEXIS 64882 (M.D. Fla. Apr. 27, 2017); 2017 WL 3608266 (M.D. Fla. 2017)

Brief Fact Summary.

Plaintiffs filed a product liability lawsuit against Defendants for injuries sustained by Plaintiffs when Plaintiff Phyllis used a blender that was designed and manufactured by Defendants. Defendants filed the instant motion to dismiss, arguing that the Plaintiffs fabricated evidence to support their claims and committed fraud on the court. During discovery, Plaintiffs requested “[a]ll accident reports and records relating to any injury allegedly caused by the product,” and “[a]ll consumer complaints of any type relating to the product.” Defendant objected to the requests as not proportional to the needs of the case. Plaintiffs filed a motion to compel the production of the information.

Synopsis of Rule of Law.

Courts may choose to deny requests for discovery that are unduly burdensome or seek information that is disproportionate to the needs of the case.

Facts.

Plaintiff Phyllis was allegedly injured while using the Nutribullet Pro 900, a blender produced by Defendant. The blender allegedly exploded and resulted in hot liquids severely burning Phyllis Cerrato’s face and upper body, as well as causing property damage to the Plaintiffs’ kitchen. Plaintiffs brought a products-liability suit against Defendant. Among other things, Plaintiffs alleged that she was unable to untwist the blender’s cup from the base to turn it off. Defendant filed the instant motion to dismiss, arguing that Plaintiffs  fabricated evidence to support their claims and committed fraud on the court. During discovery, Plaintiffs requested, among other things, (1) “[a]ll accident reports and records relating to any injury allegedly caused by the product,” and (2) “[a]ll consumer complaints of any type relating to the product.” Defendant objected to the requests as overbroad and not proportional to the needs of the case. Plaintiffs filed a motion to compel the production of the information.

Issue.

Do courts have the discretion to deny requests for discovery that are unduly burdensome or seek information that is disproportionate to the needs of the case?

Held.

Yes.

Discussion.

Courts may deny requests for discovery that are unduly burdensome or seek information that is disproportionate to the needs of the case. As a general rule, courts have broad discretion to administer the discovery process in order to maximize efficiency and resources while furthering the interests of justice. Here, Plaintiffs‘ requests as written are unduly burdensome and seek information that is disproportionate to the needs of the case. The court noted that the requests had no reasonable limitations (e.g., time limits or restrictions on the type of complaints and injuries requested). However, with such limitations in place, the request would be proportional to the needs of the case. Therefore, the court granted Plaintiffs‘ motion to compel in part, but limited the request to the five-year period before Plaintiffs‘ alleged injury and to complaints about the blender not being able to be turned off. The court found that such a limited request was not unduly burdensome and would seek only information that was proportional to the needs of the case.