Reinsdorf v. Skechers U.S.A., Inc.
- Court
- District Court, C.D. California (Federal district court)
- Decided
- 2013
- Citation
- 296 F.R.D. 604 (C.D. Cal. 2013)
- Standard applied
- Preservation and search adequacy — no sanction without improper conduct
What the court held
The court declined to reopen discovery or impose sanctions, finding that the defendants had not improperly withheld or destroyed relevant evidence. The plaintiff's evidence of discovery misconduct was insufficient to justify either remedy, and discovery remained closed.
Why
The court worked through the history of the parties' discovery and the specific allegations of withholding and destruction, and concluded that what the movant characterised as misconduct reflected the ordinary limits of a good-faith search rather than suppression. Absent improper conduct, neither reopening discovery nor sanctions was available.
Our reading — not the court’s words
Why this matters in practice
Reinsdorf is worth reading as the denominator: the great majority of ESI disputes end with a court concluding that an imperfect production was nevertheless a reasonable one. The opinion's detailed walk through what the defendants actually did is a practical description of what a defensible search looks like. It is also a caution against building a case theory around a spoliation motion that has not yet been won.
This paragraph is Legal Cyber Academy’s editorial assessment of the decision’s practical importance. The court said none of it. For what the court actually said, read the opinion.
Additional detail
Tags: reasonable search · sanctions denied · reopening discovery
Cited 58times in CourtListener’s corpus at the time this entry was compiled. Treat it as a rough measure of influence, not of correctness.
Other decisions on spoliation & sanctions and discovery & imaging
- Victor Stanley, Inc. v. Creative Pipe, Inc.District Court, D. Maryland · 2010After finding a sustained pattern of deletion, use of wiping software, and failure to preserve devices, the court granted the sanctions motion in part: it recom…
- Goodman v. Praxair Services, Inc.District Court, D. Maryland · 2009The court found a breach of the duty to preserve relevant e-mail and documents and imposed a permissive adverse-inference instruction — one allowing but not req…
- Zubulake v. UBS Warburg LLC (Zubulake V)District Court, S.D. New York · 2004The court imposed sanctions on UBS for failing to preserve and produce relevant e-mail, including an adverse-inference instruction as to messages deleted after…
- Pension Committee of the University of Montreal Pension Plan v. Banc of America Securities, LLCDistrict Court, S.D. New York · 2010The court found that several plaintiffs had failed to issue written litigation holds or to preserve and collect relevant records, and imposed graduated sanction…
- Klipsch Group, Inc. v. ePRO E-Commerce Ltd.Court of Appeals for the Second Circuit · 2018The Second Circuit affirmed monetary discovery sanctions equal to the costs the opposing party reasonably incurred in remedying the sanctioned party's non-compl…
- Cache La Poudre Feeds, LLC v. Land O'Lakes, Inc.District Court, D. Colorado · 2007The duty to preserve requires more than a mere possibility of litigation: an equivocal expression of discontent that did not produce a lawsuit for nearly two ye…
Summarised from the opinion as retrieved from CourtListener. Reference material, not legal advice. Back to the repository.