Issue: Could a court be justified in applying sanctions over a failure to produce documents in Missouri?
Area of Law:
Litigation & Procedure
Applying sanctions; Failure to produce documents; Discovery
969 S.W.2d 894
A court may be justified in applying sanctions if the record reveals a pattern of repeated disregard of a court’s order to comply with discovery. Stockmann v. Frank, 239 S.W.3d 650, 655 (Mo. Ct. App. 2007). “Where the record reveals a long course of failure to produce documents, or the facts show a pattern of repeated disregard to comply with discovery, a court is justified in applying sanctions.” Dobbs v. Dobbs Tire & Auto Centers, Inc., 969 S.W.2d 894, 899 (Mo. Ct. App. 1998); State ex rel. Lieberman v. Goldman, 781 S.W.2d 802, 808 (Mo.App.1989).
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