Two More Cases Focused on Privacy – Proportionality Update, Part 4
A short series reviewing new decisions from 2018 and 2019 addressing proportionality under the December 2015 amendments to the Federal Rules of Civil Procedure
by Matthew Verga, JD, Xact Data Discovery
In “A 2019 Update on Proportionality Cases,” we reviewed the proportionality amendment to the Federal Rules of Civil Procedure and the key takeaways from our prior case law review. In “Proportionality Arguments Must Be Fact-Based and Specific,” we begin our update with a discussion of the Hurd, Firefighters’ Retirement, and Physicians Alliance cases. In “Factors Beyond Cost,” we continued our update with a discussion of the Ramos, EEOC, and Corel cases. In this final Part, we conclude our update with a review of the Henson and Santana cases.