Coleman v. American Red Cross Case Brief
Summary of Coleman v. American Red Cross, U.S. Ct./Appeals, 6th Circuit (1994)
Cause of action: The following is a cause of action for reversal of a motion to deny discovery on PL’s part in its suit against DF, who was allegedly negligent in its causing the alleged infection of PL with HIV, and subsequently AIDS via blood transfusion.
Procedural History: Colemans filed negligence action vs. DF. During discovery, Colemans requested donor’s name and address, DF refused to provide, but district court originally ordered DF to provide such information. When they gave donor card copies to PL, one had a social security number on it, and when PL’s attempted to use it, DF moved it be prevented from doing so. Court ordered PL to return any names/addresses they found from this search.
Colemans appealed, arguing DC was wrong not to let them sue the donor. This court agreed. When remanded back to DC again, DF filed 41b motion to dismiss, which was granted, and then PL appealed the dismissal.
Facts: PL got HIV then AIDS from an unknown donor through the alleged negligence of DF. PL files discovery motion to obtain the name of the donor to see if they had HIV, so they could connect their negligence claim, but were denied.
Issue(s): Under federal rules of Civ. Pro, was there an abuse of discretion by the lower court in refusing to deny PL’s discovery motion? Which standard should be used for discovery: admissibility or relevance?
Court’s Rationale/Reasoning: Any kind of evidence, hearsay or not, is permitted in this discovery process, b/c above all else it will help the court decide the truth in this case (discovery of admissible evidence).
Rule: A court is not permitted to preclude the discovery of arguably important/relevant information solely b/c if the information were introduced at trial, it would be “speculative at best.
Also see rules 37b and 41b.
Holding: The court rules it was an abuse of discretion to deny PL motion for reversal of precluded information from discovery, as there was at least relevant information, but does not find any abuse in its discretion in refusing to grant the original request (was too burdensome and expensive).
Dissenting: Ryan believes the court should have never analyzed the case based on rules 41b and 37b only, for they do not address the sanctions the PL’s attorney should have received for blatantly violating the court order not to divulge the name of the donor who dies.