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E-⁠Discovery Case Law Library
A collection of simple, easy to understand analyses and resources on e-⁠discovery case law.
Case shelved under Proportionality

State Court Rules 3rd Party Not Allowed to Search Electronic Database

In re Methodist Primary Care Grp.
Tex. 14th Dist. Ct. App. June 21, 2018
Why This Case Is Important

Most litigation is conducted in state, not federal courts. While it’s important to be aware of the Federal Rules of Civil Procedure, states have their own rules about e-discovery, and attorneys practicing in those states must understand the rules that apply to them.

Ruling:
  • Original Order Vacated. The appellate court vacated the lower court’s discovery order on multiple grounds: the relators had not defaulted on their discovery obligations; the relators did not have possession, custody, or control over the data; there was an “undue intrusion” by allowing third-party access to another entity’s electronic database; and finally that the order’s scope was much broader than the original discovery request.
  • Beyond the Scope. The court stated, “the order authorizes discovery that is significantly broader than was requested by Associates.” By not properly scoping their request, the court found that Methodist Primary Care’s request was overly broad and not relevant to the claims at issue.
  • “Undue Intrusion.” Due to the elevated risk of “revealing private conversations, trade secrets and privileged or otherwise confidential communications,” the court determined that giving direct access to another party’s electronic storage devices would be an “undue intrusion.”
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Download the PDF version of In re Methodist Primary Care Grp. case law alert here. 

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