No exception to discovery only because party claims request is burdensome

In this insurance case, Defendant State Farm Fire and Casualty Company, objected to the Special Master’s discovery order compelling the answer to a set of interrogatories on ground of burdensomeness. The Western District of Missouri denied the motion to vacate. Labrier v. State Farm Fire & Cas. Co ., 2016 U.S. Dist. LEXIS 61246 (W.D. Mo. May 9, 2016)

Plaintiff had requested remote access to State Farm’s electronic claims system but State Farm objected that that “the identity of data fields and operation of its complex proprietary electronic claim system were highly confidential and constituted trade secrets”. The Special Master ruled that “in lieu of providing data fields or remote access, State Farm should answer interrogatories.” The interrogatories requested information regarding an estimated 150,000 claims and required the Defendant to utilize two separate databases for searching each claim.

State Farm objected that discovery was not “proportional to the needs of the case” and it was “unduly burdensome and the order penalizes State Farm for its record keeping”. In particular, Defendant cannot answer the interrogatories without complex inquiries in multiple databases.

In approving the interrogatories, the Special Master noted that if State Farm’s computerized data was not readily accessible, it was because of its “purported inability to access the data”. State Farm’s “failure to keep such records should not constitute justification to withhold relevant discovery” from Plaintiff.

State Farm moved the court to vacate or suspend the Special Master’s order but the Western District of Missouri denied the motion finding that “even if the matching must be done claim by claim, the time and cost involved does not justify preventing access to critical information.” The Court explained that “[a] litigant cannot keep its own system secret then refuse to gather the information itself.”

Labrier v. State Farm Fire & Cas. Co., 2016 U.S. Dist. LEXIS 61246 (W.D. Mo. May 9, 2016) is available at…         Open PDF

For more information, Francesca Giannoni-Crystal

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