In Re Peter Zhongren Huang v. the State of Texas

CourtCourt of Appeals of Texas
DecidedNovember 30, 2023
Docket01-22-00594-CV
StatusPublished

This text of In Re Peter Zhongren Huang v. the State of Texas (In Re Peter Zhongren Huang v. the State of Texas) 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
In Re Peter Zhongren Huang v. the State of Texas, (Tex. Ct. App. 2023).

Opinion

Opinion issued November 30, 2023

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-22-00594-CV ——————————— IN RE PETER ZHONGREN HUANG, Relator

Original Proceeding on Petition for Writ of Mandamus

MEMORANDUM OPINION

Relator Peter Zhongren Huang filed this petition for writ of mandamus,

asking that we vacate the trial court’s July 22, 2022 order compelling production of

Huang’s cell phone for inspection and imaging.1 Because the trial court did not

include reasonable limits as to scope and time and did not provide specific

1 The underlying case is James R. Huey v. FL Transportation, Inc., Rolling Frito- Lay Sales, LP, and Peter Zhongren Huang, cause number 2021-77958, pending in the 125th District Court of Harris County, Texas, the Honorable Kyle Carter presiding. protections for confidential, private, or sensitive information, we conditionally

grant the petition.

Background

This case arises from a personal injury lawsuit. Real party in interest, James

R. Huey, alleged that he was driving a pickup truck, waiting his turn at an

intersection in which all traffic lights were not working. When Huey proceeded

through the intersection, Huang, who was driving an 18-wheeler, “t-boned” Huey’s

pickup and the force of the impact spun him and his pickup into a guard rail,

causing injuries to Huey and extensive damage to his vehicle. Huang disputes this

version of events and claims the traffic lights were working.

Huey sued Huang and his employer, FL Transportation, Inc., for negligence,

negligent entrustment, negligent training, and negligent supervision. Huey alleged

that Huang was distracted while driving, based on multiple accounts that the traffic

lights were not functioning at the time of the collision, Huang’s speed of

approximately 50 mph without braking when he entered the intersection, and the

fact that Huang had more than one cell phone in the cab of his truck at the time of

the accident.

Huey requested production of Huang’s cell phone for imaging, but Huang

claimed these requests were overly broad in time or scope. Huey also sent a

preservation letter to Huang’s counsel on January 25, 2022, stating his intent to

2 conduct a “cellular image of [Huang’s] phone[s] for the 2-hour interval, one hour

preceding the wreck, and one hour following the wreck.” Huang’s counsel

responded that Huang routinely deletes his cellphone data on a daily or weekly

basis, though Huang’s counsel ostensibly agreed to preserve the two cell phones.

Huang’s counsel also asked for the name of the person to perform the imaging and

inspection. Huang’s counsel asked for a proposed protocol to address Huang’s

concerns while providing Huey with his discovery.

Huey emailed a proposed protocol on February 8, 2022, with time and scope

restrictions, which included the right for Huang to have ten days or longer to

designate “confidential information” from the extract of information and to provide

a privilege log of those items designated as confidential. The proposed protocol

also permitted redaction of confidential or privileged information by Huang.

Although Huey invited Huang’s counsel to review and revise the protocol, Huey

contends that Huang declined this invitation.

Huang produced a redacted copy of his cell phone bill from the day of the

collision, but this provided no information about data usage or which applications

were in use, nor did it provide a timestamp as to any particular data usage. Huey

issued subpoenas to the carrier for both cell phones, T-Mobile, who provided only

a single-page call log that showed incoming and outgoing calls for one phone, but

nothing concerning data usage.

3 Huey then filed a motion to compel explaining the need for forensic imaging

of Huang’s phones and the factual circumstances suggesting distracted driving. On

July 22, 2022, the trial court signed an order granting the motion to compel and

ordering Huang’s cell phones to be imaged “under a narrow window of time, using

an appropriate protocol to protect any confidential, private, or sensitive

information . . . within thirty (30) days of the entry of this Order.” Huang then

filed this petition for writ of mandamus.

Analysis

A. Standard of review and applicable legal principles

To show entitlement to mandamus relief, a relator must show that the trial

court abused its discretion and that there is no adequate remedy by appeal. See

Prudential Ins. Co. of Am., 148 S.W.3d 124, 135–36 (Tex. 2004). “Mandamus

relief is available when the trial court compels production beyond the permissible

bounds of discovery.” In re Weekley Homes, L.P., 295 S.W.3d 309, 322 (Tex.

2009).

B. Huey met the threshold showing to obtain discovery

Turning first to Huang’s third issue, he argues that the trial court improperly

compelled inspection and copying of his cell phones because Huey did not allege

that Huang failed to properly respond or show that Huang’s response to a

discovery request was inadequate. Huang also contends that discovery may not be

4 compelled without a showing that relevant, discoverable information appropriately

bears on the claims at issue.

Rule 192.3 provides for discovery of documents, which includes electronic

information relevant to the subject matter of the action. See TEX. R. CIV. P.

192.3(b) cmt. 1—1999 (“While the scope of discovery is quite broad, it is

nevertheless confined by the subject matter of the case and reasonable expectations

of obtaining information that will aid resolution of the dispute.”). Rule 196

concerns requests for production of documents, and Rule 196.4 specifically applies

to requests for production of data in electronic or magnetic form. See TEX. R. CIV.

P. 196, 196.4. When a party has made a specific request for electronic

information, the responding party must produce responsive information that is

reasonably available or object on the ground that the information cannot be

retrieved through reasonable efforts or cannot be produced in the form requested.

See Weekley Homes, 295 S.W.3d at 315; TEX. R. CIV. P. 196.4. When a specific

request for cell phone data has been lodged, and the responding party objects and

does not produce the data, the trial court “may order production subject to the

discovery limitations imposed by Rule 192.4.” Weekley Homes, 295 S.W.3d at

315.

5 1. Huey established that Huang failed to produce the requested discovery

Huang asserts that the trial court abused its discretion in compelling

production of the cell phone data because Huey failed to show that Huang,

defaulted in his obligation to produce the requested data, that the production was

inadequate, and that there is a “reasonable likelihood that a search of the [device at

issue] would reveal the information [the party] sought.” Id. at 320–21; see also In

re Kuraray Am., Inc., 656 S.W.3d 137, 142 (Tex. 2022) (holding that “to be

entitled to production of cell-phone-data, the party seeking it must allege or

provide some evidence of cell-phone use by the person whose data is sought at a

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Related

In Re Prudential Insurance Co. of America
148 S.W.3d 124 (Texas Supreme Court, 2004)
In Re Weekley Homes, L.P.
295 S.W.3d 309 (Texas Supreme Court, 2009)
In Re Honza
242 S.W.3d 578 (Court of Appeals of Texas, 2008)
In Re Clark
345 S.W.3d 209 (Court of Appeals of Texas, 2011)
in Re National Lloyds Insurance Company
507 S.W.3d 219 (Texas Supreme Court, 2016)
in Re Methodist Primary Care Group & TMH Physician Organization
553 S.W.3d 709 (Court of Appeals of Texas, 2018)

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