A Los Angeles Superior Court judge has cleared the way for Disney to dig into the post-termination work histories of two former employees, refusing to block subpoenas for their personnel files from later employers. The ruling keeps intact subpoenas aimed at studios and other production outfits where the pair landed after leaving Disney, turning a standard discrimination case into a sharp fight over how far discovery can reach when workers claim lost earnings.
Judge's ruling
Judge Dean J. Kitchens wrote that “Here, plaintiffs have put their subsequent compensation and employment information at issue by alleging that they have lost earnings,” and denied the workers’ motion to quash the subpoenas, according to MyNewsLA. Disney told the court it first tried to get the same information through depositions and document requests, but said those efforts went nowhere, the outlet reports.
Legal context
California’s Civil Discovery Act lets parties demand documents and records that are relevant or “reasonably calculated to lead to admissible evidence,” and courts frequently allow employment-related records when damages or mitigation are on the table. The statute authorizing inspection and production of documents is set out in Code of Civil Procedure §2031.010.
What the plaintiffs say
Plaintiffs Donald Stewart and Taneisha Polk accuse Disney Content Services Inc. of race discrimination, harassment, wrongful termination and retaliation, and they argued the subpoenas were overbroad and trampled on their privacy, according to MyNewsLA. Court papers state that both plaintiffs later worked for Tyler Studios LLC. Stewart’s post-Disney resume includes Blumhouse Productions and DoorDash, while Polk’s later employers include Squared Solutions and Somesuch.
Discovery vs. privacy
The plaintiffs’ lawyers said fishing through personnel files and performance reviews from later employers amounts to improper character evidence, not legitimate damages discovery. Judge Kitchens disagreed, concluding that Disney had already tried narrower discovery and that the subpoenas were not overbroad. Under Code of Civil Procedure §2017.020, courts must rein in discovery when its burden or intrusiveness clearly outweighs the likelihood of turning up admissible evidence, a balancing test that will guide any future fights over exactly what those third-party employers must hand over.
What's next
The case sits before Judge Dean J. Kitchens at the Stanley Mosk Courthouse in downtown Los Angeles, at 111 N. Hill Street, according to the Los Angeles Superior Court. With the subpoenas greenlit, the targeted employers can either comply or ask for protective orders, and any tussles over scope and privacy are likely to wind up back in Kitchens’ courtroom.
