Gadbois v. Arrow International Inc.
- John Docherty
- 0:24-cv-01662
- U.S. District Court · District of Minnesota
- 11
In Gadbois v. Arrow International Inc., Magistrate Judge Docherty granted in part and denied in part Arrow's motion to compel discovery, ordering plaintiff Jean-Paul Gadbois to provide medical authorizations, tax returns, employment records from his current job, and proof of other income, while rejecting Arrow's demands for pre-Arrow employment records and refusing to compel responses to four requests for admission that sought to relitigate a previously decided motion to dismiss.
Plaintiffs in employment discrimination cases who seek emotional distress damages and defendants seeking broad discovery of employment, medical, and financial records. Also relevant to litigants and practitioners in the District of Minnesota regarding the scope of discoverable records when a plaintiff claims non-nominal emotional distress, and the limits on using requests for admission to relitigate resolved motions.
What happened
In Gadbois v. Arrow International Inc. (Case No. 24-cv-1662), Jean-Paul Gadbois, who is 57 years old, worked as a Field Service Engineer for Arrow International Inc. starting April 3, 2023. His employment ended on June 5, 2023, after he emailed a coworker about workplace concerns. Arrow treated the email as a resignation; Gadbois says he was fired. He is now suing Arrow for age discrimination under both Minnesota and federal law, seeking more than $50,000 for emotional distress, among other damages. The case is in the discovery phase, where parties exchange information and documents before trial.
Arrow asked the court to force Gadbois to turn over a wide range of records, including employment history going back to January 1, 2020, full tax returns for the last three years, medical records from January 2020 to the present, proof of other income sources, and better answers to four formal written questions (called requests for admission). Gadbois objected to many of these requests on grounds of relevance, overbreadth, and medical privacy. The parties resolved some disputes on their own but reached a deadlock on others, leading Arrow to file its motion to compel.
Magistrate Judge Docherty granted the motion in part and denied it in part. The court ordered Gadbois to provide, within 14 days: a signed authorization for his job-search records through Indeed; paystubs, W-2 forms, wage statements, and his full personnel file from his current employer; complete state and federal tax returns (or signed authorizations for them) for the last three years; signed medical authorizations for all medical providers from January 1, 2020, to the present; and documents showing any independent income sources since January 1, 2020. The court denied Arrow's request for pre-Arrow employment records, finding them irrelevant because Gadbois's job performance is not at issue — Arrow claims he resigned rather than that it fired him for cause. The court also denied Arrow's motion to compel responses to four requests for admission, finding those requests were improper attempts to relitigate a motion to dismiss that had already been decided.
The detailed version
- Gadbois v. Arrow International Inc., No. 24-cv-1662 (JMB/JFD)
- United States Magistrate Judge John F. Docherty
- November 14, 2025
Background
Plaintiff Jean-Paul Gadbois, age 57, was employed as a Field Service Engineer by Defendant Arrow International Inc. beginning April 3, 2023. On June 5, 2023, Gadbois emailed a coworker about employment concerns; Arrow processed this as a resignation. Gadbois disputes this characterization, contending he was terminated. He brings claims under the Minnesota Human Rights Act (MHRA) and the federal Age Discrimination in Employment Act (ADEA). His damages demand includes more than $50,000 for emotional distress, plus back pay, front pay, and employment benefits.
Arrow served written discovery requests on August 14, 2025; Gadbois responded September 15, 2025. After meet-and-confer efforts resolved some but not all disputes, Arrow moved to compel (Dkt. No. 38). A hearing was held October 15, 2025.
Legal Standard
Under Federal Rule of Civil Procedure (Fed. R. Civ. P.) 26(b)(1), discovery must be relevant and proportional to the needs of the case. Under Fed. R. Civ. P. 37(a)(1), a party may move to compel when the opposing party fails to respond adequately. The moving party bears a threshold burden to show relevance; the burden then shifts to the opposing party to show the discovery is irrelevant or unduly burdensome.
Rulings on Each Category
1. Employment Records (Interrogatory No. 17, Request Nos. 8 and 11): The court ordered Gadbois to provide, within 14 days, a signed authorization for Indeed job-search records (since the records are not recoverable from Indeed directly by Gadbois), plus paystubs, W-2 forms, wage statements, and his full personnel file from his current employer. The court found that Gadbois had agreed to provide his current employer's records and that this, combined with the Indeed authorization, was sufficient for post-termination employment records. The court denied Arrow's request for employment records predating Gadbois's tenure at Arrow, finding Arrow failed to establish relevance: because Arrow claims Gadbois resigned rather than that he was disciplined or terminated for cause, his prior job performance and prior employer complaints are not at issue. The court distinguished Martin v. ReliaStar Life Ins. Co., No. 09-1578 (MJD/AJB), 2011 WL 13318490 (D. Minn. Oct. 26, 2011), where prior employment records were relevant because job performance was directly at issue.
2. Tax Returns (Request No. 14): The court ordered Gadbois to produce, within 14 days, complete state and federal tax returns with all schedules and attachments for the last three years, or signed authorizations for those returns. The court found full tax returns relevant and proportional to the mitigation-of-damages inquiry, citing Peterson v. Seagate U.S. LLC, No. 07-CV-2502(MJD/AJB), 2009 WL 3430150 (D. Minn. Oct. 19, 2009), and Henne v. Great River Reg'l Libr., No. 19-CV-2758 (WMW/LIB), 2021 WL 6804560 (D. Minn. Jan. 4, 2021). Gadbois's offer to produce only W-2s and 1099s was insufficient because he had not shown that all information in the full returns was available from those other sources.
3. Medical Records and Authorizations (Interrogatory No. 15, Request Nos. 5 and 19): The court ordered Gadbois to provide, within 14 days, signed medical authorizations for all medical providers from January 1, 2020, to the present. Although Gadbois argued he was seeking only 'garden variety' emotional distress damages and had not placed his medical condition at issue, the court found otherwise: his demand for more than $50,000 in emotional distress damages — pleaded separately from back pay and other relief — constitutes a non-nominal claim that opens his medical history to discovery. The court cited Doverspike v. Chang O'Hara's Bistro, Inc., No. 03-CV-5601 (ADM/AJB), 2004 WL 5852443 (D. Minn. July 13, 2004), and Kutz v. NGI Cap., Inc., No. 22-CV-1623 (NEB/ECW), 2023 WL 3790766 (D. Minn. June 2, 2023). Medical records were ordered only from January 1, 2020 (not January 2015 as originally requested), applying a relevance and proportionality limit.
4. Requests for Admission (RFAs) Nos. 1, 2, 5, and 6: The court denied Arrow's motion to compel further responses to all four RFAs. RFAs 1 and 2 asked Gadbois to admit statements he made in a legal brief opposing Arrow's prior motion to dismiss. The court found the objections justified, characterizing the RFAs as an attempt to relitigate an already-decided motion. RFAs 5 and 6 asked Gadbois to admit that Arrow is entitled to dismissal and to attorney's fees, respectively. The court found these were an improper attempt to circumvent the district court's prior order denying Arrow's motion to dismiss.
5. Independent Sources of Income (Request No. 4): The court ordered Gadbois to produce, within 14 days, documents showing any independent income sources received from January 1, 2020, to the present. The court agreed with Arrow that other income sources are relevant to whether Gadbois made reasonable efforts to mitigate (reduce) his damages — specifically, whether he voluntarily accepted lower-paying employment because other income reduced his incentive to seek comparable pay.
Disposition
Arrow's Motion to Compel (Dkt. No. 38) is GRANTED IN PART and DENIED IN PART.
Reviewer note from the AI+
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