Unreported / Non-Citable
Background
FCA US LLC allegedly sold vehicles equipped with seats and Seat Height Adjusters designed by Lear Corporation. According to the plaintiffs, the adjusters could break during rear-end collisions and create serious safety risks. The plaintiffs alleged that Lear notified FCA of the defect and its risks, but FCA continued selling the affected vehicles.
Richard and Evelyn Alexander, Brenda Turner, Shawn Fischer, and Troy and Shera Stone brought a putative class action asserting claims under the federal Racketeer Influenced and Corrupt Organizations Act and the Texas Deceptive Trade Practices Act, along with claims for breach of implied warranty, fraud, and unjust enrichment. After the plaintiffs served 77 requests under Federal Rule of Civil Procedure 34 seeking decades of documents, FCA and Lear moved to stay discovery.
The Court’s Holding
The court denied the motion because FCA and Lear failed to show good cause for a discovery stay under Federal Rule of Civil Procedure 26(c). Although the court acknowledged that responding to the discovery could impose a substantial burden, it concluded that a stay would merely postpone that burden rather than reduce it.
The court also rejected the defendants’ argument that their motions to dismiss would clarify or potentially dispose of the claims. The plaintiffs’ amended complaint had mooted those motions, leaving no motion to dismiss pending that could justify pausing discovery.
Key Takeaways
- A substantial discovery burden does not alone warrant a stay when postponement would not reduce the burden.
- A discovery stay based on a potentially dispositive motion is unpersuasive when no such motion remains pending.
- FCA and Lear were required to proceed with discovery because they did not establish good cause under Rule 26(c).
Why It Matters
The decision illustrates that courts may require more than the volume and historical scope of document requests to stay discovery. A party seeking a stay should explain how the stay would materially lessen an undue burden, not simply defer compliance.
It also underscores the procedural effect of an amended complaint: when amendment moots pending dismissal motions, those motions cannot support a request to halt discovery.