Wagoner v. Lewis Gale Medical Center, LLC

  • Facts: π sues ∆ for discrimination based on disability—dyslexia—and wants email records within a specific time-window and within specific search terms. ∆ objects as to the cost of the discovery gathering—$45,000. He worked there for $12.49/hr.
  • Issue: Whether the cost of discovery was warranted due to the non-proportionality to the value/needs of the case.
  • Rule: FRCP 26 something
  • Holding: Yes, discovery was warranted because ∆ failure to store information in an easily-accessible manner does not warrant a proportionality defense.
  • Reasoning: The cost for retrieving those email records was so high because ∆ stored their emails in a manner that cost a lot of money to recover.
  • Judgment: Motion to Compel Production granted.