Vidal v. Metro North Commuter Railroad
In response to a motion to compel, a court can order an employer in a Title VII employment discrimination suit to respond to interrogatories that request information about the employer's training classes. Hispanic plaintiffs, Robert Vidal and Holger Ocana, alleged that the defendant employer, Metro North, denied them acceptance into a "promotion to foreman" training class, because of discrimination, in violation of Title VII of the Civil Rights Act of 1964. The plaintiffs filed a motion to compel responses to interrogatories and production requests. The District Court ordered the defendant to indicate the number of individuals who were accepted into the training class and promoted to the position of foreman in 2007. The court expressed frustration with the defendant's "boilerplate" objections that the plaintiff's requests were overly broad, unduly burdensome and unlikely to lead to the discovery of admissible evidence. The scope of discovery is broad, pursuant to Federal Rule of Civil Procedure 26(b). The defendant's objections, wrote the court, "only [serve] to increase litigation expenses . . . potentially extend deadlines for completion of discovery unnecessarily and delay resolution." The court warned the defendant that continued failure to comply with the Federal Rules of Civil Procedures could result in discovery sanctions and costs. The court reminded the parties that they possess an ongoing duty to supplement and to correct disclosures and responses, pursuant to Federal Rule of Civil Procedure 26(e).