Chudasama v. Mazda Motor Corp.,

Facts

Chudasama (P) purchased a used minivan from a Georgia Dodge Dealer. On October 15, 1991, P was injured when her husband lost control of the van and collided with a utility pole. P filed a products liability action against Mazda (D) and alleged two defects in the minivan which resulted in the accident; the brakes were likely to cause an unexpected loss of control and the side door panels and supporting members were inadequately designed and constructed such that they were likely to crush and deform into the passenger compartment. P raised four counts of strict liability, breach of implied warranty, negligent design and manufacture, and fraud. P sought compensatory damages, pain, and suffering, loss of consortium, medical bills and loss of the vehicle. P also sought punitive damages. Discovery was engaged over a two-year period. The normal discovery abuses, however, were not controlled by the district court, and the situation quickly deteriorated into unbridled legal warfare. P's first discovery request all but asked for every document D ever had in its possession and then some. (These requests are detailed specifically by example on page 551 Yeazell 5th). D filed broad and specific objections to the discovery requests but the district court did not rule on D's objections nor did it ever give any indication that it had considered them in even the most cursory fashion. P continued its broad demands. The interrogatories that were served contained 121 numbered requests with extensive sub-requests that essentially asked 635 questions. P even sought detailed information about D’s marketing practices and strategies worldwide. D then motioned under Rule 9(b) and claimed that P failed to point to any misrepresentations by D. The District Court heard the motion but did not rule upon it. D also sought a protective order. D also began to withhold a substantial amount of information that it later conceded was properly discoverable. P then filed a motion to compel. A hearing was held, and D pleaded with the court to rule on its motions, and the court told D that if it did rule, it was inclined to issue sanctions and that it wanted the parties to confer and settle their disputes on their own. There were no rulings from the bench once again. Another status conference was held, and no rulings came from the court. More complaints and allegations were made, and eventually, P's letter to the judge resulted in an order to compel. D was given 15 days to comply on pain of default judgment. D made best efforts to comply, and D missed the deadline by a few hours. P then filed a motion for default judgment that left damages as the only issue. P's motion for sanctions was granted under Rules 37(b)(2) and 26(g). The court struck D’s answers and entered a default against D on all claims. P was granted costs and attorney fees and the only issue to be tried was damages. The Court even removed the protective order relating to D’s secret and proprietary information that was to be revealed in discovery. D eventually appealed under 28 U.S.C. Section 1292 (b). 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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