Allstate Insurance v. Superior Court

FIDEL, Judge,

specially concurring:

I concur fully in the court’s opinion. I write to add these thoughts: In its accompanying comment to Rule 26.1, our supreme court noted the importance of sanctions to the operation of the rule. The court stated its intent “that the trial courts deal in a strong and forthright fashion with discovery abuse and discovery abusers.” Ariz.R.Civ.P. 26.1 ct. cmt.

Typically, however, our rules provide judges a range of discretion to select the proper sanction for dilatory or abusive conduct. See, e.g., Ariz.R.Civ.P. 16(f), 26(f), 26.-1(g), and 37. Similarly, our case law, recognizing that general rules of prohibition require adjustment to meet the circumstances of particular cases, emphasizes that judges must use their available discretion to tailor the right sanction ease by case. See, e.g., Montgomery Ward & Co., Inc. v. Superior Ct., 176 Ariz. 619, -, 863 P.2d 911, 914 (App.1993); Nesmith v. Superior Ct., 164 Ariz. 70, 71, 790 P.2d 768, 769 (App.1990); Robinson v. Higuera, 157 Ariz. 622, 760 P.2d 622 (App.1988).

*617The trial judge in this case imposed what our lead opinion accurately describes as a “substantial sanction.” He barred further discovery by plaintiffs, precluded their use or disclosure of additional witnesses and exhibits, and ordered them to pay all of the attorneys’ fees arid costs that defendants had incurred because of plaintiffs’ delay. The trial judge then made clear, in denying defendants’ motion to impose a more extensive sanction upon reconsideration, that he thought this measured response sufficed to bring justice to the particular mix of violation and prejudice he confronted in this case.

Subsection 26.1(c), however, mandates the inflexible sanction of exclusion, whatever the circumstances, whenever the trial court finds untimely disclosure without good cause. Like my colleagues, I read the rule as rigid on this point. I add that such rigidity leaves trial judges too little elbow room to do justice. Although trial judges may well choose, in cases such as this, to impose the sanction presently mandated by subsection (c), trial judges should be trusted to recognize case by case whether a greater or lesser sanction better fits the case at hand.

The judges of Maricopa County, tellingly, have attempted to stretch their discretion under subsection 26.1(c) by expansively defining their inquiry into good cause. In published Guidelines for Rule 26.1, they have commented:

“Good cause” refers to reasons why the disclosure was not fully and timely made. In determining whether good cause has been shown, the court will weigh the willfulness of the non-disclosure and the prejudice to the opposing party.

16 Ariz.Rev.Stat.Ann., Guidelines for Rule 26.1 (Supp.1993).

Ordinarily, it is after finding no good cause that a trial judge considers willfulness and prejudice in deciding the degree of sanction. Departures from good cause can range from minor carelessness to deliberate manipulation; prejudice may be substantial, or there may be none at all. The effort by the Maricopa County judges to import what are normally disciplinary considerations into the good cause inquiry reflects some chafing at the constrictions of the rule.

The supreme court has indicated its intent to reconsider Rule 26.1 after a period of use to decide what refinements should be made to improve its function. One of those refinements, in my view, should be to restore the trial court’s discretion, in cases of late disclosure, to make the punishment fit the crime.