2018 WL 4689112
In the 2018 case Alley v. MTD Products, the Western District of Pennsylvania federal court addressed the issue of discovery standards and proportionality under Rule 26 of the Federal Rules of Civil Procedure. The case involved Alley, who sued MTD Products, the manufacturer of a snowblower, after being injured by its plastic rim. Alley claimed negligence, strict liability, and breach of warranty.
During the discovery process, Alley asked MTD to produce documents from prior lawsuits involving similar snowblower injuries. He also filed a Rule 30(b)(6) notice to question MTD's records custodians about their electronic information storage methods. MTD argued these requests were not relevant or proportional and sought a protective order, which the court granted.
The court determined that Alley's discovery requests were not proportional under Rule 26(b) and used a test to assess relevance and proportionality. It found the requests not relevant due to differences in snowblower models, injuries, and legal theories. The court also said that the requests were not proportional since they would burden MTD with undue expense, especially since MTD had already provided information from similar cases.
The court ruled that Alley's Rule 30(b)(6) notice was improper, as it sought "discovery on discovery" without showing deficiency or bad faith by MTD. The case continues to be cited as an authority on discovery standards and proportionality under Rule 26.
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