Rodriguez v. Calace
A court can restrict the plaintiff's claims, as a sanction, if the plaintiff fails to comply timely with discovery requests and discovery orders. The plaintiff, Lori Rodriguez, sued her employer, the Bridgeport Housing Authority, its executive director and her supervisor, alleging sexual harassment. The defendants moved to dismiss and argued that the plaintiff failed to comply timely with discovery requests and discovery court orders and that the plaintiff's supplemental disclosures expanded the scope of the plaintiff's claims. The defendants argued that they were severely prejudiced. The District Court denied the defendants' motion to dismiss the complaint. To remedy prejudice to the defendants, the court restricted the plaintiff's claims to whether she suffered sexual harassment at work and, if so, if that harassment caused the plaintiff to suffer a stroke or other medical event in January 2009. The District Court barred the plaintiff's allegations of emotional distress that allegedly resulted from sexual harassment or the January 2009 medical event. The District Court granted the defendants' permission to file another motion to dismiss in the future, because the plaintiff was ordered to produce medical and pharmacy records, on or before Aug. 13, 2012, and allegedly failed to respond to production requests.