In Gonzalez Gomez v. Epic Landscape Productions, a group of current and former landscape laborers brought a class action lawsuit against Epic Landscape Productions under the Fair Labor Standards Act (FLSA) and various state wage laws. The plaintiffs alleged that Epic failed to pay them overtime wages for hours worked beyond 40 per week, compensating them only at a straight-time rate. Additionally, the plaintiffs made claims under Missouri state law, citing breach of contract related to the employment of H-2B visa workers and unjust enrichment concerning unpaid wages. In response, Epic filed a motion to compel discovery, seeking more detailed information on the plaintiffs' work histories and social media accounts. Ultimately, the court granted Epic's motion in part and denied it in part, balancing the relevance of the discovery requests against the plaintiffs' objections.

The court relied on Federal Rule of Civil Procedure 26(b)(1) when making relevancy determinations in this matter, noting that relevance at the discovery stage is broadly construed to include any matter that bears on or could lead to other matters that bear on any issue in the case. When a discovery request appears relevant on its face or the discovering party establishes relevance, the burden shifts to the party resisting discovery to support its objections. As such, the court agreed with the plaintiffs that their work histories were deemed irrelevant to the core issue of overtime compensation despite Epic’s claims that they were relevant to the workers’ credibility. Specifically, the court noted that Epic failed to explain how plaintiffs’ credibility could bear on whether Epic should have paid them overtime compensation.

However, the court did find merit in Epic's requests regarding the plaintiffs' social media and messaging account details. It ruled that usernames and profile links to public accounts could provide relevant information about whether the plaintiffs engaged in non-work activities during work hours, potentially affecting their unpaid wage claims. While plaintiffs argued that Epic was attempting to conduct a "fishing expedition" by exploring their social media activity without limitations, the court noted that Epic’s interrogatories only requested hyperlinks to each plaintiff's account profile page and plaintiff's username for messaging accounts but did not seek the content of these pages. Furthermore, public postings that referenced Epic or a plaintiff's employment with Epic were deemed relevant, and no privacy or proportionality concerns were seen as being implicated because the postings were public.

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