Davis v. Precoat Metals

2002 WL 1759828 (N.D. Ill. 2002)

What's Going On?

Motion by Plaintiffs (employees) to compel discovery of discrimination complaints made against Defendant (employer) in a discrimination case under Title VII of the Civil Rights Act of 1964.

Who's Who?

Plaintiffs     :

Nicholas Davis, L.C. Alexander, Deon Page, George Hollins, and Tina Williams – African-American and Latino employees of Defendant against whom Defendant allegedly discriminated.

Defendant  :

Precoat Metals – employer of Plaintiffs.

Facts:

Plaintiffs are African-American and Latino employees of Defendant Precoat Metals. Plaintiffs filed suit against Defendant alleging that Defendant discriminated against them in violation of Title VII of the Civil Rights Act of 1964 by exposing them to a hostile work environment. Plaintiffs also claim that Defendant discriminated against them in terms of entry level placement, work assignments, promotions, and discipline. Plaintiffs filed a motion seeking discovery of discrimination complaints made against Defendant by certain employees within a four-year time period. Defendant argues that Plaintiffs' discovery requests were overly broad.

Issue:

Are discovery requests proper where they seek evidence of conduct similar to that alleged by the party seeking discovery and which occurred within a limited time period?

Decision:

Yes. Plaintiffs do not seek discovery related to all alleged discrimination practices by Defendant. Instead, Plaintiffs' discovery requests are limited to complaints alleging race and national origin discrimination filed by other employees who worked at the same plant as Plaintiffs. Also, the information sought by Plaintiffs is relevant to the establishment of a pattern of discrimination by Defendant. Because the discovery requests are narrowly tailored to the specific allegations of Plaintiffs' complaint, Plaintiffs' motion to compel discovery is granted.

Basic Rule:

Discovery requests are proper where they are narrowly tailored to specific allegations at issue in the case.

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