Commercial Litigation and Arbitration

Court Enjoys Wide Discretion to Decide If There Is a Pattern of Delay or Disobedience to Court Orders Justifying Rule 16(f) Sanctions — Denial of Sanctions for Untimely Production of Minimally Relevant Documents Upheld

From Guimaraes v. Nors, 366 F. App’x. 51(11th Cir. 2010):

Under Rule 16(f), a court may impose sanctions if a party or its attorney violates a scheduling or other pretrial order, including a discovery order. Fed.R.Civ.P. 16(f)(1)(C). We have upheld the denial of sanctions where the non-moving party had not timely produced documents but the documents in question were "of minimal relevance." SCADIF, 344 F.3d at 1130. We have held that ”district courts have discretion to decide if there is a pattern of delay or a deliberate refusal to comply with court orders or directions that justifies a sanction" under Rule 16. United States v. Samaniego, 345 F.3d 1280, 1284 (11th Cir. 2003).

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