Piacenti v. General Motors Corp.

Citations: 173 F.R.D. 221; 38 Fed. R. Serv. 3d 962; 1997 U.S. Dist. LEXIS 5581Docket: No. 94 C 2305

Court: District Court, N.D. Illinois; April 22, 1997; Federal District Court

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Plaintiff Michelle L. Piacenti's renewed motion to compel discovery from Defendants General Motors Corporation (GM) and Suzuki Motor Company regarding supplemental interrogatories and production requests related to the Suzuki Samurai has been denied. Piacenti's complaint, filed on May 9, 1994, alleges strict liability and negligence stemming from an incident on April 16, 1992, where her 1991 GEO Tracker spun out of control, leading to a collision. The defects cited include instability, lack of directional stability, and inadequate warnings from the manufacturers.

Piacenti served supplemental interrogatories and production requests on March 14, 1996, which went unanswered by GM by the initial deadline of April 14, 1996. Following multiple extensions and assurances from Defendants’ counsel, GM still failed to provide a complete response by January 16, 1997. A status hearing on September 25, 1996, mandated a response by October 4, 1996, but this was not fulfilled. Consequently, on December 31, 1996, Piacenti indicated intentions to renew her motion to compel regarding the Suzuki Samurai. However, her motion was denied without prejudice on January 16, 1997, pending the submission of an expert opinion verifying the relevance of Suzuki Samurai tests to the liability concerning the GEO Tracker, specifically detailing the usefulness of such information compared to results from other vehicles manufactured by the defendants.

Plaintiff filed a Renewed Motion to Compel on February 11, 1997, accompanied by the Affidavit of Robert L. Anderson, an expert in sport utility vehicles, who asserted that the 1991 Geo Tracker and Suzuki Samurai share design characteristics and market niches, making the requested discovery relevant to Plaintiff's claims of defects. On February 20, 1997, Plaintiff also submitted the Affidavit of John Marcosky, another expert, who noted that the Tracker is geometrically similar to the Samurai, further supporting the relevance of documents related to both vehicles and the Chevrolet S-10 Blazer in proving the defects alleged.

In response, Defendants GM and Suzuki argued on March 27, 1997, that they had produced over 10,000 documents but withheld documents concerning the Suzuki Samurai, claiming irrelevance and undue burden. The Declaration of Yoshihisa Inoue detailed the distinctions between the Tracker and Samurai, including differences in design, luxury features, engine specifications, dimensions, and suspension systems, emphasizing that the Tracker was not a successor to the Samurai.

The legal framework for discovery is grounded in Federal Rules of Civil Procedure, which allow for written interrogatories and requests for document production relevant to the case. Relevance for discovery is broader than trial admissibility, but the sought information must possess some evidentiary value to justify a motion to compel.

The scope of discovery is confined to information relevant to the subject matter of the case and must be likely to lead to admissible evidence, as established by Federal Rule of Civil Procedure 26(b)(1). Courts have ruled that relevancy in discovery is broader than in admissibility but should not permit overly broad or exploratory requests. Several cases illustrate this principle: 

1. In **Rider v. Caterpillar Tractor**, discovery of accident reports for lift trucks similar to the one involved was permitted, but not for all models due to significant differences in specifications like lift capacity and design, which made comparisons invalid.

2. **Schaap v. Executive Industries** allowed discovery of earlier models of motor homes with similar component parts, finding such information potentially relevant to claims of defects in the plaintiffs' vehicle.

3. In **Hofer v. Mack Trucks**, discovery was denied for models that lacked pertinent characteristics to the truck at issue, emphasizing the importance of similarity in design for discovery relevance.

4. **Culligan v. Yamaha Motor Corp.** affirmed that information about post-manufacture testing is discoverable if it could lead to relevant evidence, unless the models are sufficiently dissimilar.

The trial judge has broad discretion in determining the appropriateness of discovery requests, and courts generally defer to this discretion unless it is abused.

The court permitted discovery of pre- and post-manufacture testing for Yamaha's Model YT-225, finding no significant distinctions from other ATV models. In Uitts v. General Motors Corp., discovery was permitted for similar accidents involving vehicles with the same spring component as the plaintiff's defective 1970 Chevy Blazer. The plaintiff's claims regarding her 1991 GEO Tracker's defects included issues related to control and stability, leading her to seek discovery of information on the Suzuki Samurai, a different SUV model. The court required an expert opinion to establish the similarity between the Tracker and Samurai, emphasizing the need to demonstrate why Samurai test results would be more relevant than those from other vehicles.

The plaintiff submitted two affidavits asserting relevance, but they lacked specific reasoning beyond superficial similarities. The defendants contested the similarity, highlighting significant differences in engine size, wheelbase, track width, and suspension systems between the Tracker and Samurai. These disparities suggested that Samurai tests would not meaningfully inform the Tracker's handling performance. Consequently, the court concluded that the requested discovery lacked evidentiary value and was not relevant to the case, denying the motion. The court cited precedents indicating that discovery should only be allowed for vehicles that share critical component parts or defects, reinforcing that comparison between the Tracker and Samurai was inappropriate due to their substantial differences.

The Tracker and Samurai vehicles differ significantly in key specifications, including wheelbase, width, center of gravity, suspension systems, and overall dimensions. As they do not share essential components or pertinent characteristics, discovery related to the Samurai is deemed irrelevant. The court references a precedent in Hofer, where discovery was denied for predecessor models that lacked similarity to the product in question. Given the substantial differences between the Tracker and Samurai—including variations in suspension, engine, dimensions, and design—Plaintiff Piacenti's request for supplemental interrogatories and production concerning the Suzuki Samurai is denied, as it is unlikely to yield admissible evidence. The court concludes that the discovery request is not reasonably calculated to produce relevant information.