Poole v. Textron, Inc

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Brief Fact Summary.

The Plaintiff, Ryan W. Poole (Plaintiff) a golfer, brought a products liability suit against the Defendant, Textron, Inc. (Defendant), a manufacturer of golf carts. Plaintiff filed a request for attorney fees, costs, and other sanctions for discovery violations by Defendant. Plaintiff sought sanctions after Defendant objected to several discovery orders issued by the magistrate judge.

Synopsis of Rule of Law.

Sanctions, including attorneys’ fees, are justified where a party’s refusal to comply with discovery orders is not justified and the attorney has not made a reasonable inquiry into the facts of the case before signing the discovery documents.

Facts.

This was a products liability case in which Plaintiff filed suit against Defendant for alleged defects in a golf cart resulting in serious injuries to him. The presiding magistrate judge issued three discovery orders against Defendant. Defendant filed several objections to those orders with the district judge, which the district judge rejected. Plaintiff then moved for attorneys’ fees and other sanctions.

Issue.

Whether an award of expenses including attorneys’ fees and other sanctions is justified for discovery violations where the party objecting to a discovery order loses its appeal to the district judge.

Held.

The court awarded $37,000 in expenses, including attorneys’ fees, but declined to award any other sanction under the rule. A court has the authority to impose a range of sanctions including an award of expenses against both a party and its counsel to redress discovery misconduct. A Defendant’s responses and objections to a request for admissions are not justified where the defendant lodges both an objection and an answer to every request. The term control in the discovery rules is broadly construed so that a party may be obligated to produce documents requested even though it may not actually possess the documents. A party is deemed to have control if the party has a legal right or ability to retain the requested documents. A attorney signing discovery documents must make only a reasonable inquiry into the facts of the case, he need not conduct an exhaustive investigation

Discussion.

The court held that discovery sanctions must be applied diligently both to penalize those whose conduct may be deemed to warrant such a sanction and to deter those who might be tempted to such conduct in the absence of a deterrent. Thus, students should be aware that sanctions are aimed not only at the parties themselves, but at the conduct of the attorneys representing those partie