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Keywords

plaintiffdiscoveryappealmotionsummary judgmentcivil proceduremotion for summary judgment
plaintiffdiscoveryappealmotionsummary judgmentcivil proceduremotion for summary judgment

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Doe v. City of Memphis, 928 F.3d 481, 104 Fed.R.Serv.3d 124

Facts

The plaintiffs, Jane Doe No. 1, Jane Doe No. 2, and Jane Doe No. 3, alleged that the City of Memphis failed to submit their sexual assault kits (SAKs) for testing, resulting in spoliation of evidence. Each plaintiff reported a sexual assault to the Memphis Police Department (MPD), and while some kits were tested soon after the assaults, Jane Doe No. 2's kit was not tested until 2013, eleven years after her assault. The plaintiffs filed a complaint in 2013, alleging various constitutional violations, and after a lengthy discovery process, the city moved for summary judgment.

The plaintiffs, Jane Doe No. 1, Jane Doe No. 2, and Jane Doe No. 3, alleged that the City of Memphis failed to submit their sexual assault kits (SAKs) for testing, resulting in spoliation of evidence.

Issue

Did the district court err in granting summary judgment to the City of Memphis and in striking the class allegations before the plaintiffs had a meaningful opportunity to conduct further discovery?

Did the district court err in granting summary judgment to the City of Memphis and in striking the class allegations before the plaintiffs had a meaningful opportunity to conduct further discovery?

Rule

Under Federal Rule of Civil Procedure 56(d), a party may request additional time for discovery if they cannot present facts essential to justify their opposition to a motion for summary judgment. The court must consider whether the party was diligent in pursuing discovery and whether the requested discovery could change the outcome.

Under Federal Rule of Civil Procedure 56(d), a party may request additional time for discovery if they cannot present facts essential to justify their opposition to a motion for summary judgment.

Analysis

The Court of Appeals found that the plaintiffs were diligent in pursuing discovery and that the district court did not adequately consider the factors relevant to the plaintiffs' request for additional discovery. The court noted that the plaintiffs had not been given a meaningful opportunity to review the investigative files that could provide evidence of discriminatory practices by the city. The court emphasized that the plaintiffs' claims required a demonstration of discriminatory intent, which could be established through further discovery.

The Court of Appeals found that the plaintiffs were diligent in pursuing discovery and that the district court did not adequately consider the factors relevant to the plaintiffs' request for additional discovery.

Conclusion

The Court of Appeals reversed the district court's decision and remanded the case for further proceedings, concluding that the plaintiffs should have been allowed additional discovery to support their claims.

The Court of Appeals reversed the district court's decision and remanded the case for further proceedings.

Who won?

The plaintiffs prevailed in the appeal because the Court of Appeals determined that they had not been given a fair opportunity to conduct necessary discovery before the district court ruled on the summary judgment.

The plaintiffs prevailed in the appeal because the Court of Appeals determined that they had not been given a fair opportunity to conduct necessary discovery before the district court ruled on the summary judgment.

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