in Re Steadfast Insurance Company

CourtCourt of Appeals of Texas
DecidedMay 18, 2009
Docket01-09-00235-CV
StatusPublished

This text of in Re Steadfast Insurance Company (in Re Steadfast Insurance 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 Steadfast Insurance Company, (Tex. Ct. App. 2009).

Opinion

Opinion issued May 18, 2009



In The

Court of Appeals

For The

First District of Texas



NO. 01-09-00235-CV



IN RE STEADFAST INSURANCE COMPANY, Relator



Original Proceeding on Petition for Writ of Mandamus



MEMORANDUM OPINION (1)



This proceeding arises from the trial court's grant of a motion to compel production filed by real party in interest, David Law. Relator, Steadfast Insurance Company ("Steadfast"), asserts that request for production number 28 and interrogatory number 8 are overbroad and unduly burdensome. We conclude that request for production number 28 and interrogatory number 8 are overbroad because they are not properly limited by time and geographic expanse. Accordingly, we conditionally grant mandamus relief.

Background



Forest Oil Corporation ("Forest") owned and operated the 466-B Oil Drilling platform off the coast of Galveston, Texas. Law served as project supervisor to plug and abandon the well. However, the well could not be plugged because an old fishing tool was lodged within.

While trying to remove the tool, Marion Yeager was killed by exploding metal fragments. Law assisted in Forest's initial investigation of the accident, was interviewed by Minerals Management Service investigators regarding the accident and was present when the pipe involved in the accident was tested. Subsequently, Forest terminated Law.

Yeager's heirs sued Forest. Counsel for the heirs noticed Law's deposition. However, Law could not be found in time for his deposition, and he was not deposed. Forest and its insurers settled with Yeager's heirs. The settlement agreement explicitly omitted Law and his employer, Drilling & Completion Supervisors, Inc. ("DCS").

Forest sued Law and DCS, claiming common law indemnity in excess of $3,000,000. The indemnity claim is premised upon the allegation that Forest incurred liability to Yeager's heirs because of Law's negligence. Yeager's heirs also filed suit against Law and DCS, asserting wrongful death and survivor claims. Law filed third party claims against Steadfast, Forest's primary coverage insurer, and Associated Electric & Gas Insurance Services Limited ("AEGIS"), Forest's excess coverage insurer. In his third party claims, Law sued Steadfast and AEGIS for violation of the Texas Insurance Code and the Texas Deceptive Trade Practices Act, breach of common law duty of good faith and fair dealing, and breach of contract. Law sought a judgment from the trial court holding Steadfast responsible to Law for indemnity against any judgment against him in the suit.

Law served Steadfast with requests for production and interrogatories. Steadfast timely served its objections and responses, withholding statements, and privilege logs. Thereafter, Law moved to compel production of the requested documents and information. Request for production number 28 and interrogatory number 8 provide:

Request No. 28: Your entire claim file for each claim in which you have been alleged to have acted in bad faith or in breach of an insurance policy with respect to a claim against an employee, borrowed servant, consultant or subcontractor for your insured for the period beginning on January 1, 1998 through the present.



Interrogatory

No. 8: Identify each insurance claim in which you have been alleged to have acted in bad faith or in breach of an insurance policy with respect to a claim against an employee, borrowed servant, consultant or subcontractor for your insured for the period beginning on January 1, 1998 through the present including for each such claim the court and case number; contact information for all parties, attorneys, adjusters, insurance agents, insurance brokers, insureds and claimants involved.



After in camera review of the documents designated by Steadfast and AEGIS as privileged, the trial court signed an order granting the motion to compel. The order imposes specific time and context constraints on many of the requests for production and interrogatories. In its order, the trial court restricted request for production number 28 and interrogatory number 8 accordingly: "Discovery is ordered as to such matters that developed into a lawsuit to which Steadfast or AEGIS have been a party."

On February 20, 2009, Steadfast moved for reconsideration of the court's order by producing a supplemental affidavit. That affidavit demonstrates that there are 5,586 claim files that Steadfast would have to examine individually to satisfy request for production number 28 and interrogatory 8, at a cost of $160,000.

Motion to Compel Production Steadfast contends that request for production number 28 and interrogatory number 8 are overbroad and unduly burdensome. Law asserts that the trial court tailored request for production number 28 and interrogatory 8 and that they are not overbroad or unduly burdensome.

Mandamus relief is available only to correct a "clear abuse of discretion" when there is no adequate remedy by appeal. Walker v. Packer, 827 S.W.2d 833, 839 (Tex. 1992) (orig. proceeding). Clear abuse of discretion occurs when a trial court "reaches a decision so arbitrary and unreasonable as to amount to a clear and prejudicial error of law." Id. (quoting Johnson v. Fourth Court of Appeals, 700 S.W.2d 916, 917 (Tex. 1985) (orig. proceeding)). The reviewing court may not substitute its judgment for that of the trial court when reviewing factual issues. Id. at 839-40. Even if the reviewing court would have decided the issue differently, it cannot disturb the trial court's decision unless the decision is shown to be arbitrary and unreasonable. Id. at 840. Mandamus relief is proper when a trial court erroneously orders the production of privileged information that materially affects the rights of the aggrieved party. Id. at 843. A discovery order compelling overly broad discovery "well outside the bounds of proper discovery" is an abuse of discretion remedied by mandamus. Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815 (Tex. 1995).

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in Re Steadfast Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-steadfast-insurance-company-texapp-2009.