Unreported / Non-Citable
Background
Maurice Daronte Davis, a state prisoner proceeding without counsel, filed a civil rights action in the Eastern District of California. The case proceeds on a Fourteenth Amendment procedural due process claim against defendants Madrigal and Hamblin, who allegedly deprived Davis of good time credits without providing him an opportunity to call witnesses. The dispute centers on a May 5, 2023 disciplinary hearing.
On March 10, 2026, Davis served defendants with a Request for Production of Documents, Set One, and interrogatories directed to each defendant. Defendants served their responses on April 24, 2026. About a month after the deadline to serve discovery requests, Davis served a second set of requests for production, to which defendants responded in June 2026. Davis then filed a motion to compel, also after the applicable deadline, seeking full answers to Interrogatory Nos. 4, 7, and 8 and production of documents and body-worn camera footage related to Requests for Production Nos. 1, 5, and 8, along with sanctions. Defendants opposed, and Davis did not file a reply.
The Court’s Holding
The court granted the motion to compel in part. It denied a further response to Interrogatory No. 4, finding that defendant Hamblin had provided a substantive answer explaining that Davis was found guilty of a lesser included charge as an act of leniency, and that Davis’s mere assertion that the response was evasive did not carry his burden. However, the court found defendants’ objections to Interrogatories Nos. 7 and 8 were not well taken. Those interrogatories sought identification of chronos regarding lower bunk/tier status that Hamblin relied upon and an explanation of why permanent chronos from 2019 and 2022 were not acknowledged. The court rejected the argument that the requests were vague or unintelligible, noting that California regulations and CDCR’s Operations Manual define chronos, and that defendants’ own records showed awareness of Davis’s lower-tier/lower bunk medical chrono. The court ordered Hamblin to provide further responses to both interrogatories.
The court denied the motion as to the requests for production. It held it could not compel production of body-worn camera footage that defendants declared did not exist after a reasonable search, absent evidence to the contrary from Davis. As to RFP No. 8, which sought copies of Title 15 regulations, the court denied the request as moot because defendants had served Davis with the requested regulation. The court also declined to impose sanctions, finding Davis had not established that any sanctions under Rule 37(c)(1) were warranted. Finally, the court directed the Clerk to update the docket to reflect the correct spelling of defendant Madrigal’s name.
Key Takeaways
- A party moving to compel must do more than assert that a discovery response is evasive; it must demonstrate how or why the response is incomplete or inadequate.
- Objections that interrogatories are vague or unintelligible will fail where the terms used are defined in applicable regulations and the responding party’s own records show an understanding of the subject matter.
- A court cannot compel the production of documents or footage that the responding party declares do not exist after a reasonable search, absent contrary evidence from the requesting party.
- A discovery dispute over publicly available legal authority becomes moot when the responding party provides the requested material, even while maintaining its objections.
- Even when a motion to compel is granted in part, sanctions under Rule 37 are not automatic and require a showing that they are warranted.
Why It Matters
This order illustrates the practical application of federal discovery standards in prisoner civil rights litigation, where pro se plaintiffs must still meet their burden to show why responses are deficient. It underscores that boilerplate vagueness objections may fail when the requested information is defined in governing regulations and within the responding party's knowledge.
The decision also reaffirms the limits of judicial power in discovery: courts cannot order production of materials that do not exist, and a party's dissatisfaction with a response does not itself establish inadequacy. The ruling provides guidance on how courts in the Eastern District of California evaluate motions to compel in cases involving prison disciplinary proceedings, including the principle that a dispute over publicly available legal authority becomes moot once the material is produced, and that sanctions under Rule 37(c)(1) require an affirmative showing rather than following automatically from a partial grant.