CIGANA CORP. v. Spears

838 S.W.2d 561, 1992 Tex. App. LEXIS 2627, 1992 WL 228901
CourtCourt of Appeals of Texas
DecidedSeptember 21, 1992
Docket04-92-00153-CV
StatusPublished
Cited by37 cases

This text of 838 S.W.2d 561 (CIGANA CORP. v. Spears) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CIGANA CORP. v. Spears, 838 S.W.2d 561, 1992 Tex. App. LEXIS 2627, 1992 WL 228901 (Tex. Ct. App. 1992).

Opinions

ON RELATORS’ MOTION FOR WRIT OF MANDAMUS

CHAPA, Justice.

This is an original proceeding in which relator, Cigna Corporation and its subsidiaries, seeks this court to protect its attorney-client and attorney work product privileges in discovery proceedings.

The underlying lawsuit was instituted by Tom McCorkle, an independent insurance agent, against Cigna for breach of contract. McCorkle alleged that Cigna induced him to enter its COMPAR program by which McCorkle became an exclusive insurance salesman for Cigna. McCorkle claimed that after he joined the COMPAR program Cigna cancelled the program.

In response to McCorkle’s requests for production, Cigna offered some documents but claimed the attorney-client privilege protected it from producing certain memos to and between its in-house counsel and Cigna employees. Cigna also alleged that some of the documents had been prepared in anticipation of litigation involving other lawsuits. The trial court, Judge Carleton Spears, overruled Cigna’s attorney-client objections because Cigna failed to prove that the employees of the corporation were its representatives as defined by Tex.R.Civ.Evid. 503(a)(2). Judge Spears also found that McCorkle established the fraud exception to the attorney-client privilege. Cigna brought this proceeding to prevent production of the documents it contends are privileged communications.

MANDAMUS JURISDICTION

Mandamus is available only to correct a clear abuse of discretion by the trial court or to correct the violation of a duty imposed by law if the relator has no other adequate remedy at law. Walker v. Packer, 827 S.W.2d 833, 839 (Tex.1992); Johnson v. Fourth Court of Appeals, 700 S.W.2d 916, 917 (Tex.1985). An abuse of discretion occurs when the trial court acts so unreasonably and arbitrarily that its decision is a clear and prejudicial error of [564]*564law. Walker v. Packer, 827 S.W.2d at 839; Johnson v. Fourth Court of Appeals, 700 S.W.2d at 917. It is the appropriate remedy when the trial court has erroneously granted discovery of non-discoverable documents. Remedy by appeal in that case is ineffective, because once revealed, the documents cannot be protected. Walker v. Packer, 827 S.W.2d at 843.

DOCUMENTS CREATED PRIOR TO ANTICIPATION OF THIS LITIGATION

The first issue to be decided is whether the attorney work product privilege can be applied to documents generated for other lawsuits or whether they must have been created with regard to the lawsuit in which the privilege is claimed. The supreme court has recently held that the privilege is of a continuing duration, and the documents need not have been generated specifically in defense of this case. Owens-Corning Fiberglas v. Caldwell, 818 S.W.2d 749, 751-52 (Tex.1991). However, to be protected by the work product privilege, the documents must have been created in anticipation of some litigation. Texas Dep’t of Mental Health & Mental Retardation v. Davis, 775 S.W.2d 467, 471 (Tex.App. — Austin 1989, orig. proceeding).

The February 6, 1990, document from Linda S. Kaiser, while appearing to be attorney work product, does not show that it was prepared in anticipation of litigation— past or present. No evidence was offered to indicate this fact. Two other documents, which are not dated, not addressed to anyone, and not signed by anyone, appear to contain legal discussions. The final document, dated January 7, 1991, is a new file memorandum. The final documents — the two undated ones and the January 7, 1991, document — fail to disclose that they were prepared by an attorney. No testimony was given to establish that they were. Cigna failed to carry its burden as to these documents. The trial court did not abuse its discretion in ordering production of these documents.

ATTORNEY-CLIENT PRIVILEGE: CORPORATE REPRESENTATIVE

We now reach the issue of major concern in this case: who is a corporate representative for purposes of the attorney-client privilege and how must it be established?

The attorney-client privilege exists only as it is found in the Texas Rules of Civil Evidence. Tex.R.Civ.Evid. 501(4). The attorney-client privilege is found in rule 503. It states:

A client has a privilege to refuse to disclose and to prevent any other person from disclosing confidential communications made for the purpose of facilitating the rendition of professional legal services to the client (1) between himself or his representative and his lawyer or his lawyer’s representative ... (4) between representatives of the client or between the client and a representative of the client....

Tex.R.Civ.Evid. 503(b). The rule defines client as including a corporation. Tex.R.Civ.Evid. 503(a)(1). A representative of the client is defined as “one having authority to obtain professional legal services, or to act on advice rendered pursuant thereto, on behalf of the client.” Tex.R.Civ.Evid. 503(a)(2).

The burden of proof falls on the party asserting the privilege and seeking to limit discovery. Walker v. Packer, 827 S.W.2d at 840; Johnson v. Fourth Court of Appeals, 700 S.W.2d at 917. This burden can be met by presenting evidence to the trial court in the form of testimony, affidavits, depositions, interrogatories, et cetera, or by the documents themselves. See Weisel Enters., Inc. v. Curry, 718 S.W.2d 56, 58 (Tex.1986). Communications are not presumed to be privileged: the only presumption contained in the rule is that “[t]he person who was the lawyer or the lawyer’s representative at the time of the communication is presumed to have authority to claim the privilege but only on behalf of his client.” Tex.R.Civ.Evid. 503(c).

There are no published Texas cases interpreting the definition of a representative of [565]*565the client under rule 503(a)(2).1 In Texas Dep’t of Mental Health & Mental Retardation v. Davis, 775 S.W.2d 467 (Tex.App. — Austin 1989, orig. proceeding), the court found that relator did not conclusively prove that the employees preparing a report and communicating it to the attorney were client representatives. The court said that the representative capacity and participation of the employees was unclear; that the record did not clearly establish whether they made the investigation on a superintendent’s order, whether they were persons entitled to engage in confidential communications, or whether they were needed participants to facilitate rendition of the legal services; and that the record did not conclusively establish that the communication was intended to be confidential. Id. at 473.

The dissent in this case misplaces the burden of proof. It seeks to create a presumption that would shift the burden of proof away from the party seeking to deny discovery, contrary to established legal principles. See Walker v. Packer, 827 S.W.2d at 840; Johnson v.

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Cite This Page — Counsel Stack

Bluebook (online)
838 S.W.2d 561, 1992 Tex. App. LEXIS 2627, 1992 WL 228901, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cigana-corp-v-spears-texapp-1992.