In Davis v. Safety Holdings, Inc. (D. Md. 2026), the court reinforced the heightened protections afforded to non-parties in discovery, granting Lyft’s motion to quash a deposition subpoena and denying a motion to compel further production.
Plaintiff sued Safety Holdings, Inc. under the Fair Credit Reporting Act, alleging that it provided inaccurate information to Lyft, Inc. in a background report that incorrectly suggested he had a physical or mental disability. According to the complaint, Lyft relied on that report in deactivating the plaintiff’s driver account in February 2025. Lyft was not a party to the lawsuit, but because it had received the report and made the deactivation decision, the plaintiff subpoenaed Lyft for documents and a corporate deposition concerning its evaluation of the report, its deactivation decision, and its internal policies.
The court emphasized that Rule 45 imposes a “more demanding” proportionality standard for non-party discovery in it’s opinion, requiring parties to demonstrate that the requested information cannot be obtained from other sources. Lyft argued that the deposition and document requests imposed an undue burden because Lyft had already produced 300 pages of responsive material, including communications with the plaintiff, driver status updates, copies of the background checks, and other records bearing on causation. The court rejected the plaintiff’s argument that Lyft had waived its objections through boilerplate responses or a transcription error in one objection. Instead, the court emphasized that nonparties are entitled to “special solicitude” in discovery disputes and that subpoenas directed to nonparties are subject to a heightened proportionality analysis. Because much of the requested information was duplicative, available from the parties themselves, or already produced by Lyft, requiring additional deposition testimony and expansive document production would impose an undue burden on a non-party without a corresponding benefit to resolving the key issue of causation. The court therefore granted Lyft’s motion to quash and denied the plaintiff’s motion to compel.
This decision underscores a critical boundary in modern discovery: even relevant information may be off-limits when sought from non-parties if it is duplicative or accessible elsewhere. Courts continue to prioritize efficiency and fairness by limiting discovery that unnecessarily drags third parties into litigation.
Reach out to Caitlin Oyler, Counsel at CODISCOVR. Caitlin has over a decade of experience providing high-level advice to clients regarding all phases of the eDiscovery life cycle and managing high-profile document collections, reviews, and productions.
