Can a case be lost before a plaintiff ever has a chance to take any discovery? A federal district court in Maryland granted summary judgment to the Social Security Administration despite refusing to allow the plaintiff to take any discovery whatsoever. However, the Fourth Circuit Court of Appeals reversed and sent the case back to the district court where the plaintiff will at least have opportunity to develop a factual record in support of her claims. The case is Works v Colvin, No 12-1288 (April 24, 2013).