Segota v. Young
Segota v. Young, 2020 UT App 105 (Harris, J.)
Plaintiff sued Defendants (the car dealership and its bond company) after she discovered a truck she had purchased did not have the features the dealership had purportedly agreed to provide. Plaintiff did not serve initial disclosures until weeks after the deadline for fact discovery had passed, and after one of the defendants had filed a motion for summary judgment. Plaintiff then served initial disclosures, along with various motions of extensions of time that she never submitted to the court for decision. The other defendant also moved for summary judgment, and following oral argument, the district court denied Plaintiff’s various motions for extensions and held that Plaintiff’s initial disclosures were provided too late for meaningful discovery and that this violation warranted a sanction under Utah Rule of Civil Procedure 26(d)(4), which provides that if a party fails to timely disclose, the party may not use the undisclosed witness or material. The court then granted Defendants’ summary judgment motions and dismissed the case with prejudice. The Utah Court of Appeals affirmed, holding:
- The district court did not abuse its substantial discretion in denying Plaintiff’s various motions for extensions, even though Defendants did not oppose them in writing, because it was within the court’s discretion to find that Plaintiff’s asserted grounds were insufficient to warrant any extensions of time.
- The district court did not abuse its discretion in sanctioning Plaintiff under Rule 26(d)(4) because the rule specified the penalty for Plaintiff’s discovery violation and the district court determined there was no good cause for Plaintiff’s violation and that the violation harmed Defendants.
- The district court properly granted the Defendants’ summary judgment motion because the sanction under rule 26(d)(4) prevented Plaintiff from using undisclosed witnesses or material, meaning she had no evidence in support of her case.