Mancia v. Mayflower Textile Servs. Co.
253 F.R.D. 354, 2008 WL 4595175, 2008 U.S. Dist. LEXIS 83740 (2008)
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Rule of Law:
Federal Rule of Civil Procedure 26(g) imposes an affirmative duty on attorneys to conduct a reasonable inquiry before signing any discovery request, response, or objection. Boilerplate objections lacking a particularized factual basis violate this rule and result in the waiver of the objection.
Facts:
- Glenda Mancia and several other employees worked for Mayflower Textile Services Co. and its related entities.
- The employees alleged that Mayflower knowingly failed to compensate them for overtime work.
- The employees also claimed that Mayflower made illegal deductions from their wages.
- These alleged actions by Mayflower regarding pay and deductions formed the basis for a wage and hour dispute.
Procedural Posture:
- Glenda Mancia and others ('Plaintiffs') filed a collective action against Mayflower Textile Services Co. and others ('Defendants') in the U.S. District Court for the District of Maryland.
- The complaint alleged violations of the Fair Labor Standards Act and Maryland state wage laws.
- Plaintiffs served interrogatories and document production requests on Defendants.
- After receiving what they considered 'inadequate' responses containing numerous boilerplate objections, Plaintiffs filed Motions to Compel Supplemental Responses against each of the Defendants.
- Defendants Mayflower, Lunil, and Mehta filed a Consolidated Response to Plaintiffs' motions.
- The district court referred the case to Chief Magistrate Judge Paul W. Grimm for resolution of all discovery disputes.
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Issue:
Do boilerplate objections to discovery requests, such as "overly broad and unduly burdensome," made without a particularized factual basis, violate an attorney's duty under Federal Rule of Civil Procedure 26(g) to conduct a reasonable inquiry and state objections with specificity?
Opinions:
Majority - Paul W. Grimm
Yes, boilerplate objections to discovery requests made without a particularized factual basis violate an attorney's duty under Federal Rule of Civil Procedure 26(g). Rule 26(g) requires an attorney to certify that after a 'reasonable inquiry,' any discovery response or objection is consistent with the rules, not for an improper purpose, and is proportional to the needs of the case. The court reasoned that making generic, non-specific objections, such as 'overly broad and unduly burdensome,' is prima facie evidence of a Rule 26(g) violation because if an attorney had conducted a proper inquiry and found facts to support such an objection, those facts should have been stated with particularity as required by Rules 33 and 34. The failure to do so results in a waiver of the objection. The court explained that this rule is designed to curb discovery abuse and the excessive costs of litigation that arise from uncooperative, adversarial conduct. While the Defendants waived their objections, the court also invoked its sua sponte duty under Rule 26(b)(2)(C) to ensure discovery is proportional, ordering counsel to confer and develop a 'discovery budget' and plan appropriate for the case.
Analysis:
This memorandum opinion is highly significant for its forceful revitalization of Rule 26(g) as a primary tool for policing discovery abuse. By condemning the common practice of lodging boilerplate objections, the decision puts litigators on notice that such reflexive, non-reflective conduct is sanctionable and constitutes waiver. It strongly advocates for a shift from purely adversarial discovery tactics to a more cooperative, cost-conscious approach, emphasizing counsel's professional responsibility to prevent discovery from becoming disproportionately expensive. The opinion's framework for creating a 'discovery budget' provides a practical model for implementing the proportionality principles of the Federal Rules, likely influencing how magistrate judges manage discovery disputes in the future.
