Costco Wholesale Corp. v. Ditmars
In a premises negligence suit against Costco, a special magistrate found Costco willfully disregarded discovery orders and recommended, as a sanction, that Costco produce all of its non-privileged policies and procedures even if beyond the scope of the request and even if irrelevant. The Third DCA granted certiorari and quashed, holding that a trial court may not order carte blanche discovery of irrelevant or confidential materials as a discovery sanction.
Key facts
- Costco was sued by Ditmars in a premises negligence case; a special magistrate found Costco willfully disregarded discovery orders and recommended that Costco produce all non-privileged policies and procedures as a sanction.
- The trial court ordered Costco to produce all policies and procedures even if outside the scope of the discovery request and irrelevant to the action.
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Why it matters
This decision gives corporate defendants a clear certiorari vehicle when a trial court, frustrated by discovery conduct, orders wholesale production of company policies and procedures untethered to the pleadings. It… — full analysis with a trial
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