In Re Gateway Logistics, Inc. and Gateway Freight Solutions, Inc. v. Christopher Patrick Smay Republic Cargo, A…

Summary

The court held that the trial court abused its discretion by compelling production and inspection of electronic devices and telephone records without making findings required to balance asserted privacy interests against the plaintiffs’ discovery needs. The court required consideration of relevance, compelling need, alternative sources, and the least intrusive means of obtaining the information, as well as the nonparty status of Smay’s wife. It vacated the challenged discovery order and remanded for findings and further proceedings.