In Spurlock v. Wexford Health Sources, Inc., Plaintiffs filed a class action lawsuit against Defendant, a medical contractor providing services to jails and prisons, claiming that Defendant denied medication for opioid use disorder to incarcerated individuals. The lawsuit alleges violations of the Eighth and Fourteenth Amendments and seeks compensatory and punitive damages, as well as legal fees. When Defendant refused to comply with Plaintiffs’ written discovery requests seeking communications of high-level executives and corporate documents, Plaintiffs filed a motion to compel, which the court granted.

In this case the court’s analysis turned on Federal Rule of Civil 26(b)(1), which allows parties to obtain discovery on any matter relevant to their claims or defenses as long as its proportional to the case's needs, considering the importance of the issues and the parties’ resources. Despite the sensitive nature of communications between high-level executives, the court rejected Defendant's argument that such data was irrelevant or duplicative and ruled the data was relevant for Plaintiffs’ case. The court further opined that Defendant’s ability to run complex eDiscovery searches to filter out duplicative information alleviates any concerns of reviewing and producing duplicative information.

Regarding financial records, Plaintiffs sought extensive financial information from Defendant to support their claims for punitive damages. Defendant objected, arguing that this was premature and not proportional to the case’s needs. However, the court, following persuasive authority, ruled plaintiffs were entitled to discovery of financial records because they made a prima facie case for punitive damages.

Spurlock is an interesting case because it demonstrated that courts’ analysis of Rule 26(b)(1) is driven by the context of the case. Here, the court considered Defendant’s status as a large corporation with sophisticated eDiscovery capabilities before ruling in favor of individual defendants. As competence in eDiscovery increasingly becomes an expectation of corporate parties, expect to see more courts denying their oppositions to motions to compel due to those parties’ own eDiscovery capabilities.     

If your organization is seeking support with eDiscovery, our team has solutions to address all phases of the discovery process. At CODISCOVR, we deliver client-focused, defensible, and scalable solutions using advanced technology and intelligent review practices to meet eDiscovery, document review, and information governance needs in a manner that reduces the risks and costs associated with electronically stored information. Reach out to Nicholas Berenato, associate attorney, CODISCOVR. Nick focuses his practice on information governance and electronic discovery in the construction, higher education, financial services, antitrust, government investigations, white-collar, insurance defense, and health care and life sciences industries.