Primoris Energy Services Corporation v. Air Products and Chemicals, Inc.

CourtDistrict Court, S.D. Texas
DecidedSeptember 3, 2025
Docket3:24-cv-00156
StatusUnknown

This text of Primoris Energy Services Corporation v. Air Products and Chemicals, Inc. (Primoris Energy Services Corporation v. Air Products and Chemicals, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Primoris Energy Services Corporation v. Air Products and Chemicals, Inc., (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT September 03, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk GALVESTON DIVISION

PRIMORIS ENERGY SERVICES § CORPORATION, § § Plaintiff. § § V. § CIVIL ACTION NO. 3:24-cv-00156 § AIR PRODUCTS AND CHEMICALS, § INC., § § Defendant. §

OPINION AND ORDER This lawsuit concerns the construction of an ammonia production facility developed by Air Products and Chemicals, Inc. (“APCI”) in Texas City, Texas. APCI and Primoris Energy Services Corporation entered into a series of contracts by which Primoris agreed to perform various construction services at the facility. Primoris filed this lawsuit, alleging that it completed the work but was not paid. APCI has asserted counterclaims, alleging that Primoris’s lack of skilled and consistent labor, quality-control personnel, and other inefficiencies led to defective work and project delays. Pending before me is a discovery dispute. APCI has requested all versions of the Power BI dashboards or project dashboards. See Dkt. 40 at 2. Power BI is a data visualization software that generates visual representations of data from external sources. At the August 19, 2025 oral hearing that I held to address this discovery issue, APCI’s counsel displayed a dashboard produced by Primoris in another matter. The dashboard presents information in a visually appealing format concerning a project’s progress. For a number of reasons, Primoris opposes APCI’s request for the dashboards related to work performed at the facility. First, Primoris insists that “[t]he requested Dashboard is software, not a document.” Dkt. 40 at 3. Primoris argues that software is not subject to production under the Federal Rules of Civil Procedure. Second, Primoris argues that the federal rules do not require it to “generate, create, or produce a document not already in existence in the way th[at] APCI’s request requires.” Id. Third, Primoris maintains that the request is not reasonably calculated to lead to the discovery of admissible evidence. I will address each objection in turn. Before I do that, let me briefly highlight the relevant federal rules at issue in this discovery fight. The purpose of pretrial discovery is to “make a trial less a game of blind man’s buff and more a fair contest with the basic issues and facts disclosed to the fullest practicable extent.” United States v. Procter & Gamble Co., 356 U.S. 677, 682 (1958). For that reason, “[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party’s claim or defense and proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). Rule 34 provides for the discovery of “documents or electronically stored information—including writings, drawings, graphs, charts, photographs, sound recordings, images, and other data or data compilations.” Fed. R. Civ. P. 34(a)(1)(A) (emphasis added). “[C]ontrol of discovery is committed to the sound discretion of the trial court.” Van Duzer v. U.S. Bank Nat’l Ass’n, 582 F. App’x 279, 283 (5th Cir. 2014). Turning to Primoris’s objections, I first address the argument that the requested dashboard is not a document.1 “[A]lthough Rule 34 was amended in 1970 to add ‘data compilations’ to the list of discoverable documents, there was no suggestion that ‘data compilations’ was intended to turn all forms of ‘data’ into a Rule 34 ‘document.’” Williams v. Sprint/United Mgmt. Co., 230 F.R.D. 640, 650 (D. Kan. 2005). So how do we determine whether the dashboards are a data compilation that falls within the scope of Rule 34?

1 Primoris recognizes that any versions of the dashboard that exist in PDF form or hard copy are documents that must be produced under Rule 34. Noting that it “does not regularly maintain screenshots of the data visualizations generated by Power BI,” Primoris objects to opening the software, generating a dashboard as of a specific date, and then producing a screenshot of that particular dashboard. Dkt. 40 at 3. As explained by the Sedona Principles2: The best approach to understanding what is a document is to examine what information is readily available to the computer user in the ordinary course of business. If the employee can view the information, it should be treated as the equivalent of a paper “document.” Data that can be readily compiled into viewable information, whether presented on the screen or printed on paper, is also a “document” under Rule 34. However, data used by a computer system but hidden and never revealed to the user in the ordinary course of business should not be presumptively treated as a part of the “document,” although there are circumstances in which the data may be relevant and should be preserved and produced.

The Sedona Principles: Best Practices Recommendations & Principles for Addressing Electronic Document Production (Sedona Conference Working Group Series 2004), SK071 ALI-ABA 363, 405. Because the dashboards at issue contain data that is easily compiled into viewable information, the dashboards are considered documents under Rule 34. Next, Primoris contends that, as a threshold matter, Rule 34 does not require a responding party to create documents. Although that is an accurate statement of the law,3 there is a critical distinction between creating new documents and “requiring a party to query an existing database to produce reports for opposing parties.” Mervyn v. Atlas Van Lines, Inc., No. 13 C 3587, 2015 WL 12826474, at *6 (N.D. Ill. Oct. 23, 2015). While “a party should not be required to create completely new documents, that is not the same as requiring a party to query an existing dynamic database for relevant information. Courts regularly require parties to produce reports from dynamic databases.” Apple Inc. v. Samsung Elecs.

2 “Created by a leading group of judges, lawyers, and academics, the Sedona Principles are recognized as a foundational guide for courts and lawyers confronting the challenges related to e-discovery.” Salzgitter Mannesmann Int’l (USA) Inc. v. Sun Steel Co., No. 3:22-cv-00030, 2022 WL 3041134, at *2 n.1 (S.D. Tex. Aug. 2, 2022). 3 See Mir v. L-3 Commc’ns Integrated Sys., L.P., 319 F.R.D. 220, 227 (N.D. Tex. 2016) (“As a general matter, a party cannot invoke Rule 34(a) to require another party to create or prepare a new or previously non-existent document solely for its production.”). Co., No. 12-cv-0630, 2013 WL 4426512, at *3 (N.D. Cal. Aug. 14, 2013).4 This case law persuades me. APCI is simply asking Primoris to extract information from its computer system; APCI is not engaging in an impermissible effort to have Primoris create a new document. Accordingly, I hold that APCI’s request for the dashboards is permissible under Rule 34. Finally, Primoris complains on relevance grounds, arguing that the dashboards are “highly susceptible to manipulation” and do not provide “an accurate representation of any overall Project metrics.” Dkt. 40 at 3. I am not convinced. A central issue in this case is whether APCI impacted Primoris’s productivity on the project and delayed certain work. “[A] request for discovery should be considered relevant if there is any possibility that the information sought may be relevant to the claim or defense of any party.” Camoco, LLC v. Leyva, 333 F.R.D. 603, 606 (W.D. Tex. 2019) (quotation omitted); see also Schlagenhauf v. Holder, 379 U.S. 104

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Related

United States v. Procter & Gamble Co.
356 U.S. 677 (Supreme Court, 1958)
Schlagenhauf v. Holder
379 U.S. 104 (Supreme Court, 1965)
Charles Van Duzer v. U.S. Bank National Ass
582 F. App'x 279 (Fifth Circuit, 2014)
Williams v. Sprint/United Management Co.
230 F.R.D. 640 (D. Kansas, 2005)
United States v. Wright Motor Co.
536 F.2d 1090 (Fifth Circuit, 1976)

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Primoris Energy Services Corporation v. Air Products and Chemicals, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/primoris-energy-services-corporation-v-air-products-and-chemicals-inc-txsd-2025.