Williams v. City of Birmingham

2 Citing cases

  1. Volp v. Sasser

    Case No. 3:18-cv-689-J-32JRK (M.D. Fla. Nov. 30, 2020)

    Thus, to demonstrate that NCSO leadership was on notice, Volp needed to submit evidence showing a pattern of NCSO officers using excessive force on pretrial detainees (i.e., a pattern of officers violating detainees' Fourteenth Amendment rights). See Williams v. City of Birmingham, 323 F. Supp. 3d 1324, 1332 (N.D. Ala. 2018) ("A prior incident may be relevant to a municipality's knowledge of the need for further training and supervision only insofar as the incident gave rise to a similar constitutional violation."). Volp points to two prior incidents involving the excessive use of force on non-threatening inmates.

  2. Jordan v. Comm'r, Miss. Dep't of Corr.

    947 F.3d 1322 (11th Cir. 2020)   Cited 81 times
    Holding that compelling the Georgia Department of Corrections to identify execution-drug supplier would impose undue burden

    Federal courts in this circuit have uniformly applied this principle. See Am. Fed. of State, County and Mun. Employees (AFSCME) Council 79 v. Scott , 277 F.R.D. 474, 476 (S.D. Fla. 2011) ("Federal courts ... have treated the scope of discovery under a subpoena [a]s the same as the scope of discovery under Rule 26."); Williams v. City of Birmingham , 323 F. Supp. 3d 1324, 1329 (N.D. Ala. 2018) ("The scope of permissible discovery with respect to a Rule 45 subpoena is that which is set forth in [Federal Rule of Civil Procedure] 26(b)(1) [.]"). As indicated by the language of Rule 26, the relevance of information sought in discovery depends on the claims asserted in the underlying action and the legal standards that govern those claims.