Prejudicial Discovery Rulings

ChatGPT (AI) Analysis

 

The AI-generated analysis of Judge Kevin Miller’s orders in your case strongly supports the conclusion that the discovery denials and delays were deeply prejudicial to Plaintiffs—both procedurally and substantively. This is especially true with respect to the suppression of call detail records and other cell phone metadata that could have substantiated claims of civil conspiracy, spoliation, and coordinated misconduct.

I. Overview of Prejudicial Discovery Rulings

Across the orders issued between July and December 2021, Judge Miller consistently issued rulings that:

  • Quashed subpoenas (e.g., to phone carriers like AT&T) that would have yielded vital call detail records (CDRs) and geolocation metadata.

  • Denied motions to compel, even when there was forensic evidence of deleted text messages and admitted gaps in discovery.

  • Refused to delay depositions, despite known incidents of ambush tactics using previously undisclosed documents.

  • Applied asymmetrical standards, permitting Defendants to evade basic discovery obligations while holding Plaintiffs to a rigid interpretation of the rules.

These cumulative decisions received bias scores ranging from –5 to –8, suggesting systemic procedural favoritism toward Defendants at nearly every key discovery inflection point.

II. Specific Impact: Loss of Call Detail Record (CDR) Evidence

The December 13, 2021 order (Bias Score: –7) is particularly important. Judge Miller granted Defendants’ motion to quash Plaintiffs’ subpoena to AT&T, which sought CDRs and metadata for Defendant Renee Stevenson during the relevant timeframe.

Consequences of This Ruling:

  • Plaintiffs lost the opportunity to obtain independent, timestamped proof of communications between Defendants, which is crucial for conspiracy claims.

  • The ruling dismissed Plaintiffs’ narrowed and targeted discovery efforts as “overly broad,” despite having reduced the timeframe and eliminated content requests.

  • Judge Miller accepted Defendants’ claims (that relevant records were already produced) without reviewing the discrepancies highlighted in Plaintiffs’ forensic evidence.

Combined with other discovery delays (e.g., denial of motions to compel on Sept. 10 and Dec. 21, 2021), this created a discovery vacuum that directly undermined Plaintiffs’ ability to prove:

  • Coordinated misconduct among Defendants;

  • The timing and context of communications related to the defamatory letters;

  • Whether message deletion patterns were innocent or conspiratorial.

III. Legal and Evidentiary Prejudice

The December 6, 2022 order (Bias Score: –8) further demonstrates the prejudice. Despite forensic evidence and Sean’s own admission of deleting relevant texts, the Court:

  • Minimized the loss of evidence, stating the missing texts caused only “minimal” prejudice.

  • Declined to issue an adverse inference, despite precedent (e.g., Miller v. Lankow, 801 N.W.2d 120) supporting it where intentional deletion occurred.

This effectively erased the evidentiary value of the phone records Plaintiffs attempted to obtain earlier—records that were denied through prior discovery rulings.

IV. Causal Chain of Harm to Plaintiffs’ Case

  1. Plaintiffs issued subpoenas and filed motions to compel in 2021 seeking phone records and discovery clarifications.

  2. Judge Miller denied or delayed nearly all of them, often with no meaningful review of the evidence.

  3. By 2022, key CDRs were no longer available from carriers due to retention limits (typically 12–18 months).

  4. Judge Miller then ruled, in December 2022 and June 2023, that Plaintiffs had insufficient evidence to survive summary judgment.

  5. These rulings directly rewarded Defendants’ spoliation and obstructive tactics, and ultimately resulted in dismissal of Plaintiffs’ claims.

Conclusion

Judge Miller’s pattern of denying or delaying Plaintiffs’ discovery rights, especially regarding phone records and metadata, was not merely procedural—it was materially prejudicial. It prevented the development of a full evidentiary record and allowed Defendants to benefit from their own failure to preserve and produce key evidence.

These rulings may form the basis for:

  • A judicial conduct complaint under Canon 2.2 and 2.3 (failure to maintain impartiality and fairness).

  • An argument on appeal that the court’s discovery rulings materially affected the outcome, justifying reversal or vacatur of summary judgment under Minn. R. Civ. P. 56.

ChatGPT 4o

Scroll to Top