Williams v. Lawson et al, No. 3:2021cv05536 - Document 245 (W.D. Wash. 2024)

Court Description: ORDER denying Plaintiff's 221 Motion for Non-Dispositive Discovery Sanctions. Signed by Judge Marsha J. Pechman. **6 PAGE(S), PRINT ALL** (Carlos Williams, Prisoner ID: 973053) (KRA)

Download PDF
Williams v. Lawson et al Doc. 245 1 2 3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE 8 9 10 CARLOS WILLIAMS, Plaintiff, 11 12 13 14 CASE NO. C21-5536 MJP ORDER DENYING MOTION FOR SANCTIONS v. LORI LAWSON, et al., Defendants. 15 16 17 This matter comes before the Court on Plaintiff’s Motion for Discovery Sanctions. (Dkt 18 No. 221.) Having reviewed the Motion, Defendants’ Response (Dkt. No. 223), the Replies (Dkt. 19 No. 225, 227), and all supporting materials, the Court DENIES the Motion. 20 Plaintiff Carlos Williams seeks an order of sanctions against Defendants with regard to 21 their supplemental responses to several of his Requests for Admissions (RFAs). The Court 22 previously issued an order compelling further answers (Dkt. No. 212), and Williams believes that 23 24 ORDER DENYING MOTION FOR SANCTIONS - 1 Dockets.Justia.com 1 certain of Defendants’ supplemental responses are inadequate and therefore sanctions should 2 issue. The Court reviews the issues raised in Williams’ Motion in the context of each RFA. 3 RFA No. 3. Williams notes that Defendants’ response to RFA No. 3 “binds the 4 defendant[s].” (Mot. at 2.) The Court notes that there is no action to be taken and no relief to be 5 granted. 6 RFA No. 4. Defendants have now provided a lengthy response to this RFA, which seeks 7 an answer as to whether “Plaintiff was brutally assaulted at CBCC.” Defendants deny that 8 Williams was brutally assaulted, but admit that Williams’ assailant was given a “serious 9 infraction for aggravated assault.” (Dkt. No. 221-1 at 44.) As the Court interprets and construes 10 this latter part of Defendants’ response, they have admitted that Williams was assaulted. The 11 Court finds that no further action is necessary on this RFA, given that Defendants have provided 12 a full response. Williams may disagree with the response, but that alone is not grounds to order a 13 different response or sanctions. It is up Williams to convince the fact finder that Defendants’ 14 responses are ultimately not credible or false. Sanctions are not properly issued, given that 15 Defendants have provided a complete response. 16 RFA No. 6. Defendants have now provided a more complete response to this RFA that 17 asks Defendants to admit or deny that “inmate Wallace was brutally assaulted at CBCC.” 18 Defendants deny Wallace was brutally assaulted, but admit that “an inmate started assaulting Mr. 19 Wallace . . .” (Dkt. No. 221-1 at 45.) Williams points to a declaration from Wallace himself that 20 appears to cast doubts on Defendants’ response. (See Dkt. No. 16.) But now that Defendants 21 have provided a binding response, it is up to Williams to convince the fact finder that 22 Defendants’ response is not credible or false. Sanctions are not properly issued, given that 23 Defendants have provided a complete response. 24 ORDER DENYING MOTION FOR SANCTIONS - 2 1 RFA. Nos. 7 & 9. Williams acknowledges that Defendants have now denied RFA No. 7 2 and admitted to RFA No. 9, but argues that their responses are false. Now that Defendants have 3 provided binding responses, it is up to Williams to convince the fact finder that Defendants’ 4 responses are not credible or false. Sanctions are not properly issued, given that Defendants have 5 provided complete responses. 6 RFA No. 8. Williams’ RFA No. 8 seeks an admission or denial that his “assailant was not 7 charged with any crime resulting from the brutal assault.” (Dkt. No. 221-1 at 45.) Defendants 8 have now provided an admission that the Clallam County Sherriff filed a referral for prosecution 9 of Williams’ assailant for Assault-2, but that the Prosecutor’s Officer declined to prosecute for 10 the reasons set forth in a separate document Defendants identify. (Id.) Defendants’ response is 11 not necessarily a model of clarity, but as the Court interprets and construes it, they have admitted 12 that Williams’ assailant was not charged with any crime. The Court finds that no sanctions 13 should issue, given that Defendants’ have admitted that Williams’ assailant was not charged with 14 any crime. 15 RFA No. 16. Williams has served Defendants a revised version of RFA No. 16, and 16 Defendants response has not yet been presented to the Court. Thus, any motion to compel or 17 motion for sanctions as to RFA No. 16 is premature. 18 RFA Nos. 17 & 18. Williams takes issue with Defendants’ denial of RFA No. 17 and 19 admission of RFA No. 18, but merely points to his disagreement with whether they are 20 defensible positions or not. Now that Defendants have provided binding responses, it is up to 21 Williams to convince the fact finder that Defendants’ responses are not credible or false. 22 Sanctions are not properly issued, given that Defendants have provided complete responses. 23 24 ORDER DENYING MOTION FOR SANCTIONS - 3 1 RFA No. 22. Williams disagrees with the merits of Defendants’ response to RFA No. 22, 2 but has not identified any failure to provide a complete response. Now that Defendants have 3 provided a binding response, it is up to Williams to convince the fact finder that Defendants’ 4 response is not credible or false. Sanctions are not properly issued, given that Defendants have 5 provided a complete response. 6 RFA No. 32: Williams disagrees with the merits of Defendants’ denial of RFA No. 32, 7 but has not identified any failure to provide a complete response. Now that Defendants have 8 provided a binding response, it is up to Williams to convince the fact finder that Defendants’ 9 response is not credible or false. Sanctions are not properly issued, given that Defendants have 10 11 provided a complete response. RFA No. 33. Williams takes issue with Defendants’ denial of RFA No. 33, which seeks 12 an admission or denial that the “assailant of Plaintiff[,] Alex Burton[,] stomped on Plaintiff’s 13 head.” (Dkt. No. 221-1 at 51.) Defendants’ Response brief indicates that Defendants now admit 14 that Burton stomped on Williams’ head. (Dkt. No. 223 at 9.) As Defendants concede, they should 15 have made this admission earlier had they engaged in a more thorough review of the evidence. 16 Although that may be grounds for sanctions, the Court finds that the failure to investigate was 17 not done for an improper purpose and declines to impose sanctions. The admission now binds 18 Defendants. 19 RFA No. 34. In response to RFA No. 34, Defendants now deny that Burton jumped up 20 and down on Williams’ head. Williams believes that the video evidence contradicts Defendants’ 21 denial. But now that Defendants have provided a binding response, it is up to Williams to 22 convince the fact finder that Defendants’ response is not credible or false. Sanctions are not 23 properly issued, given that Defendants have provided a complete response. 24 ORDER DENYING MOTION FOR SANCTIONS - 4 1 RFA No. 35. In response to RFA No. 35, Defendants now admit that Williams “was in 2 rehab to learn to walk again.” (Dkt. No. 221-1 at 52.) The Court finds no basis to award 3 sanctions now that Defendants have provided a binding response. 4 RFA Nos. 36, 38, & 39. Defendants now deny RFA Nos. 36, 38 & 39, and Williams 5 believes these responses are false. But now that Defendants have provided binding responses, it 6 is up to Williams to convince the fact finder that Defendants’ responses are not credible or false. 7 Sanctions are not properly issued, given that Defendants have provided complete responses. * 8 * * 9 The Court finds that Defendants’ amended responses to the RFAs outlined in Williams’ 10 Motion do not warrant sanctions. As the Court has explained, Defendants have now committed 11 to positions on these RFAs and it is up to Williams to demonstrate to the finder of fact that they 12 are incomplete, inaccurate, or false. But because Defendants have provided what appear to be 13 complete responses, sanctions are not properly awarded. The Court therefore DENIES the 14 Motion. 15 In reviewing Defendants’ responses and amended responses to the RFAs, the Court 16 wishes to remind Defendants that Williams—as an incarcerated person—does not have equal 17 access to much of the information cited to in their responses, and that he is entitled to understand 18 Defendants’ positions on key questions presented in this case. The Court notes that Defendants 19 continue to offer obtuse responses to many of the RFAs, rather than simply admitting or denying 20 some rather straightforward and relevant questions. Failing to provide honest and direct answers 21 wastes judicial and party resources that should be spent getting to the merits of this case. To this 22 end, the Court warns both Parties that if a party fails to admit to an RFA that the requesting party 23 later proves to be true (as Williams contends is the case for several of Defendants’ RFA 24 ORDER DENYING MOTION FOR SANCTIONS - 5 1 answers), the “requesting party may move that the party who failed to admit pay the reasonable 2 expenses, including attorney’s fees, incurred in making that proof.” Fed. R. Civ. P. 37(c)(2). 3 Though there are exceptions, the Court “must so order” expenses to be paid. Id. 4 The clerk is ordered to provide copies of this order to all Plaintiff and counsel. 5 Dated April 2, 2024. 6 A 7 Marsha J. Pechman United States Senior District Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 ORDER DENYING MOTION FOR SANCTIONS - 6

Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.