in Re: Reynolds Metal Company

CourtCourt of Appeals of Texas
DecidedApril 15, 2004
Docket14-04-00001-CV
StatusPublished

This text of in Re: Reynolds Metal Company (in Re: Reynolds Metal Company) 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: Reynolds Metal Company, (Tex. Ct. App. 2004).

Opinion

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed April 15, 2004

Petition for Writ of Mandamus Conditionally Granted and Memorandum Opinion filed April 15, 2004.

In The

Fourteenth Court of Appeals

____________

NO. 14-04-00001-CV

IN RE REYNOLDS METALS COMPANY, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

M E M O R A N D U M  O P I N I O N

Relator Reynolds Metals Company seeks a writ of mandamus directing the Judge of the 212th District Court, Cause No. 03-CV-0043, to vacate her order of December 19, 2003, which compels Reynolds Metals to comply with requests for production.  Reynolds Metals contends that the trial court abused her discretion in requiring the production of documents because the requests were overbroad and irrelevant.  On January 13, 2004, we stayed the discovery order pending our orders.  As we explain below, after reviewing the record, we find the discovery requests overly broad, and we conditionally grant the writ. 


I.          Background

The underlying suit involves premises and products liability claims by Gabriel and Virginia Salais (Salais) against 66 defendants.  During discovery, Salais propounded 136 requests for production on all of the defendants.  In response, Reynolds Metals filed objections stating that the requests for production were overbroad, unduly burdensome, vague and ambiguous.  Reynolds Metals objected to the discovery because Salais had not provided it specific information regarding Salais=s relationship with its premises including, when he was on the premises, where he was on the premises, who employed him, and how he became exposed to any toxic substances.

In response to Reynolds Metals= objections, Salais filed a motion to compel.  He claimed he requested specific documents reasonably calculated to lead to the discovery of admissible evidence and that his 136 requests for production were narrowly-tailored to the years during his exposure to cancer-causing chemicals and substances.

On December 19, 2003, the trial court held a hearing to consider the objections and motion to compel.  Without making any changes to the discovery requests, the trial court denied all of Reynolds Metals= objections and ordered it to fully answer the requests for production. 

II.        Availability of Mandamus Relief


Mandamus is available to correct a clear abuse of discretion when the relator has no adequate remedy at law.  Canadian Helicopters, Ltd. v. Wittig, 876 S.W.2d 304, 305 (Tex. 1994) (orig. proceeding).  The burden of establishing an abuse of discretion and an inadequate appellate remedy is on the party resisting discovery, and this burden is a heavy one.  Id.  A clear abuse of discretion occurs when an action is Aso arbitrary and unreasonable as to amount to a clear and prejudicial error of law.@  CSR Ltd. v. Link, 925 S.W.2d 591, 596 (Tex. 1996) (orig. proceeding). 

Generally, the scope of discovery is within the trial court=s discretion.  Dillard Dep=t Stores, Inc. v. Hall, 909 S.W.2d 491, 492 (Tex. 1995) (orig. proceeding).  However, the trial court must make an effort to impose reasonable discovery limits.  In re Am. Optical Corp., 988 S.W.2d 711, 713 (Tex. 1998) (orig. proceeding).  The trial court abuses its discretion by ordering discovery that exceeds that permitted by the rules of procedure.  Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815 (Tex. 1995) (orig. proceeding). 

III.       Analysis

A.        Waiver

Salais served a 36-page document on all defendants which included 136 requests for production.  In his motion to compel, Salais claimed that his requests were narrowly-tailored to the years during which Salais was exposed to cancer-causing chemicals and substances. In this proceeding, Salais argues that Reynolds Metals waived its objections to the discovery by not making clear objections and asserting numerous unfounded objections.  See Tex. R. Civ. P. 193.2(e).  But, based on the objections to the discovery requests, the responses to Salias=s requests for production, and the transcript of the December 19 hearing, we conclude that Reynolds Metals clearly presented its discovery objections to the trial court.


Salais also argues that Reynolds Metals waived its objections by failing to produce some evidence to the trial court in support of its objections.  At the hearing on objections to written discovery, the Aparty making the objection or asserting the privilege must present any evidence necessary to support the objection . . . .@  Tex. R. Civ. P. 193.4(a).  Reynolds Metals produced no evidence at the hearing.  The trial court had before it only Reynolds Metals= argument, its motion for protection, and its objections and responses to discovery.  However, this is not necessarily fatal to Reynolds Metals= claim.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

In Re CSX Corp.
124 S.W.3d 149 (Texas Supreme Court, 2003)
In Re Union Pacific Resources Co.
22 S.W.3d 338 (Texas Supreme Court, 2000)
In Re Sears, Roebuck and Co.
123 S.W.3d 573 (Court of Appeals of Texas, 2003)
CSR LTD. v. Link
925 S.W.2d 591 (Texas Supreme Court, 1996)
In Re Xeller
6 S.W.3d 618 (Court of Appeals of Texas, 1999)
In Re American Optical Corp.
988 S.W.2d 711 (Texas Supreme Court, 1998)
Texaco, Inc. v. Sanderson
898 S.W.2d 813 (Texas Supreme Court, 1995)
Dillard Department Stores, Inc. v. Hall
909 S.W.2d 491 (Texas Supreme Court, 1995)
Canadian Helicopters Ltd. v. Wittig
876 S.W.2d 304 (Texas Supreme Court, 1994)

Cite This Page — Counsel Stack

Bluebook (online)
in Re: Reynolds Metal Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-reynolds-metal-company-texapp-2004.