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Texaco, Inc. v. Sanderson
Citations: 898 S.W.2d 813; 38 Tex. Sup. Ct. J. 672; 1995 Tex. LEXIS 82; 1995 WL 317693Docket: 94-0618, 94-0696
Court: Texas Supreme Court; May 25, 1995; Texas; State Supreme Court
Relators Texaco, Inc., Star Enterprise, Texaco Refining and Marketing, Inc., and Texaco Chemical Company filed two mandamus petitions with the Supreme Court of Texas, challenging trial court discovery rulings in a lawsuit involving claims of gross negligence related to asbestos exposure. The plaintiffs, including the widow and children of Tony Graffagnino and the widow and son of Vernon Rieve, allege that their relatives suffered from asbestos-related diseases and cancer due to toxic exposure while employed at Texaco's Port Arthur refinery. The plaintiffs sought documents authored by John Sexton, Texaco's corporate safety director from 1957 to 1987, concerning safety and environmental issues. Texaco objected, arguing the request was overly broad, irrelevant, and burdensome. The trial court granted the plaintiffs' motion to compel document production, leading to the submission of 2,500 pages of related documents. Texaco’s subsequent motion for reconsideration was denied, and the court ruled that claims of privilege were waived. The relators contended that the request lacked specificity and was not limited to the substances or relevant timeframes related to the plaintiffs' claims, as it included documents created after the decedents' employment and did not focus solely on the refinery in question. The Supreme Court conditionally granted relief on both petitions. Defendants produced various documents related to safety practices, which plaintiffs argued were necessary to demonstrate defendants' corporate "state of mind" regarding employee safety, not limited to exposure to toxic substances. However, the discovery request was deemed overly broad and not sufficiently relevant to the case, which centers on allegations of gross negligence regarding asbestos and other toxins. Plaintiffs’ request for all documents authored by a specific individual on safety lacked limitations and failed to show relevance to the case, particularly regarding unrelated topics like fire training. Defendants agreed to provide relevant documents reflecting their attitudes towards the specific risks involved. The trial court's ruling requiring broader production was considered a clear abuse of discretion, with defendants lacking an adequate remedy on appeal. The court also ruled that defendants did not waive their privilege claims due to the overbreadth of the discovery request, as they were not required to assert privilege against an inappropriate request. Thus, the court conditionally granted writs of mandamus directing the trial court to vacate its orders that compelled broader discovery and denied privilege claims, with action required from the trial court in compliance with this opinion.