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Toyota Discovery Appeals Overruled, Minnesota Court Affirms Magistrate Orders

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Summary

Toyota Motor Sales, U.S.A., Inc. filed two appeals challenging nondispositive discovery orders issued by Magistrate Judge John F. Docherty on November 26, 2025 and December 4, 2025. The District Court applied the 'clearly erroneous or contrary to law' standard under Fed. R. Civ. P. 72(a) and D. Minn. LR 72.2(a)(3), found neither order met that threshold, and overruled both of Toyota's objections while affirming both discovery orders. The ruling demonstrates the substantial deference federal courts afford magistrate judges on discovery matters in trademark counterfeiting litigation.

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Toyota Motor Sales, U.S.A., Inc. appealed two magistrate judge discovery orders: one from November 26, 2025 concerning subpoenas to third-party Toyota dealers, and another from December 4, 2025 denying Toyota's motion to compel discovery related to Interrogatory No. 39. The district court applied the 'extremely deferential' standard and found neither order 'clearly erroneous or contrary to law.' Toyota's objections (Dkts. 785, 786) were overruled and the discovery orders (Dkts. 759, 769) were affirmed.

Parties engaged in trademark counterfeiting litigation should note that magistrate judge discovery rulings receive substantial deference on appeal; the 'clearly erroneous' standard under Rule 72(a) requires showing more than mere disagreement with the magistrate's reasoning. Litigants facing unfavorable discovery rulings should focus on demonstrating clear error or contrary-to-law findings rather than arguing the magistrate simply reached the wrong conclusion.

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Apr 24, 2026

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Feb. 26, 2026 Get Citation Alerts Download PDF Add Note

Toyota Motor Sales, U.S.A., Inc. v. Allen Interchange, LLC, Applegate Supply, Patriot Parts of Texas, Bluestone Auto Products, OEM Parts Company, Factory Parts Direct, Autoworks Distributing, and Defendants DOES 1–10

District Court, D. Minnesota

Trial Court Document

dUNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA

Toyota Motor Sales, U.S.A., Inc., No. 22-cv-1681 (KMM/JFD)

Plaintiff,

v.

Allen Interchange, LLC, Applegate Supply,
Patriot Parts of Texas, Bluestone Auto
Products, OEM Parts Company, Factory Parts
Direct, Autoworks Distributing, and
Defendants DOES 1–10,

Defendants. ORDER

Allen Interchange, LLC,

Counterclaimant,

v.

Toyota Motor Sales, U.S.A., Inc., and Toyota
Motor North America, Inc.,

Counterclaim Defendants

Toyota Motor Sales, U.S.A., Inc., and Toyota Motor North America, Inc. (collectively,
“Toyota”) has filed two appeals of nondispositive Orders issued by United States Magistrate
Judge John F. Docherty. (Dkt. 785 (Objection to Order on Discovery Motions (Dkt. 759));
Dkt. 786 (Objection to Order (Dkt. 769)).) In the first, Toyota asks this Court to partially
overturn Judge Docherty’s November 26, 2025 discovery order and allow Toyota to serve
subpoenas on third-party Toyota dealers. Toyota claims that the November 26 discovery order is
the product of two errors: (1) an erroneous conclusion that Toyota could obtain the requested
documents from Defendant Allen Interchange, LLC, despite evidence that Allen did not have, or
had destroyed, the responsive information; and (2) an erroneous determination that the dealer
subpoenas would have an in terrorem effect based only on Allen’s speculation, and contrary to
record evidence. (Dkt. 785.) In the second appeal, Toyota asks the Court to reverse Judge
Docherty’s December 4, 2025 discovery order denying Toyota’s motion to compel discovery

related to Toyota’s Interrogatory No. 39. Toyota argues that the December 4 Order is also the
product of two errors: (1) the Court erred by relying upon a prior ruling addressing requests for
different information than the information sought by Interrogatory No. 39; and (2) the Court
erred by failing appropriately to determine the relevance of the information sought. (Dkt. 786.)
The Court has carefully reviewed the underlying discovery orders (Dkts. 759, 769), the
motion practice and other relevant docket entries bearing upon those orders,1 the transcript of the
hearing on these matters, Toyota’s objections (Dkts. 785–86), and Allen’s responses (Dkts. 788,
797). Based on the Court’s review and applying the “extremely deferential” standard of review,
Subramanian v Tata Constituency Servs., Ltd., 352 F. Supp. 3d 908, 919 (D. Minn. 2018), the
Court finds that neither discovery order Toyota appeals is “clearly erroneous or contrary to law,”

Fed. R. Civ. P. 72(a); D. Minn. LR 72.2(a)(3). Toyota’s objections are, therefore, overruled, and
the discovery orders are affirmed.
Accordingly, IT IS HEREBY ORDERED THAT
1. Toyota’s Objections (Dkts. 785, 786) are OVERRULED.
2. The discovery orders (Dkts. 759, 769) are AFFIRMED.

1 With respect to the first appeal (Dkt. 785) see the documents at the following
docket entries: 343, 618, 622, 637, 639, 640, 714, 793. For the second appeal (Dkt. 786),
see the documents at the following docket entries: 125, 130, 224, 663, 665, 666, 673,
675, 676, 714.
Date: February 26, 2026 s/Katherine Menendez
Katherine Menendez
United States District Judge

CFR references

Fed. R. Civ. P. 72(a)

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Last updated

Classification

Agency
DMN
Filed
February 26th, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Substantive
Docket
0:22-cv-01681

Who this affects

Applies to
Legal professionals Manufacturers Retailers
Industry sector
3361 Automotive Manufacturing 4231 Wholesale Trade
Activity scope
Trademark enforcement Discovery disputes Civil litigation
Geographic scope
US-MN US-MN

Taxonomy

Primary area
Intellectual Property
Operational domain
Legal
Topics
Consumer Protection Antitrust & Competition

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