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Coleman v. American Red Cross

United States Court of Appeals for the Sixth Circuit
23 F.3d 1091 (1994)


Facts

Cheryl Coleman (plaintiff) sued the American Red Cross (Red Cross) (defendant) in a federal district court, alleging she contracted a deadly virus as the result of a blood transfusion from an infected Red Cross donor. Coleman's lawyer wanted to discover the donor's identity in order to win a lucrative settlement or judgment for Coleman and increase his attorney's fee. The Red Cross withheld the donor's identity, fearing that breaching the donor’s privacy could substantially prejudice its ability to attract future donors. The court issued a protective order, requiring the Red Cross to deliver redacted donor records to Coleman, but prohibiting Coleman from using the records to identify the donor. The Red Cross delivered the records to Coleman's lawyer but inadvertently failed to redact some vital information. The lawyer breached the protective order by using that information to discover the donor's identity. When the court learned of this breach it issued an injunction that prohibited Coleman from using the donor's identification for any purpose. Coleman appealed to the United States Court of Appeals for the Sixth Circuit. The circuit court invalidated the injunction and remanded the case. On remand, the Red Cross contended that violation of the protective order substantially prejudiced the Red Cross’s interests. The district court granted the Red Cross's motion to dismiss Coleman's case, citing Federal Rules of Civil Procedure 37(b) and 41(b), as well as the court's inherent power to impose sanctions for contumacious misconduct. Coleman appealed the dismissal to the circuit court.

Rule of Law

Issue

Holding and Reasoning (Guy, J.)

Dissent (Ryan, J.)

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