Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

depositiondiscoverytrialaffidavitmotioncompliancewrit of mandamus
depositiontrialcompliancewrit of mandamus

Related Cases

Warpar Mfg. Corp. v. Ashland Oil, Inc., 606 F.Supp. 852
View Case »
In re Corrugated Container Antitrust Litigation, 643 F.2d 195, 31 Fed.R.Serv.2d 632, 1981-1 Trade Cases P 63,966
View Case »
McKibbins v. United States, Not Reported in Fed. Supp., 2013 WL 5550124
View Case »
Yablonski v. United Mine Workers of America, 454 F.2d 1036, 78 L.R.R.M. (BNA) 2911, 147 U.S.App.D.C. 193, 66 Lab.Cas. P 12,223
View Case »
People v. Albanese, 104 Ill.2d 504, 473 N.E.2d 1246, 85 Ill.Dec. 441
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

In re American Airlines, Inc., 634 S.W.3d 38, 65 Tex. Sup. Ct. J. 58

Facts

Dr. Donald Arnette, the passenger, brought action against American Airlines, claiming that one of its gate agents improperly accessed his personal information and harassed him. Arnette sought to depose Elise Eberwein, the Executive Vice President of American Airlines Group, asserting that she had relevant knowledge. American Airlines moved to quash the deposition, arguing that Eberwein was an apex executive with no unique knowledge of the case. The trial court denied the airline's motion and compelled the deposition, leading to American Airlines seeking mandamus relief from the Supreme Court.

Dr. Donald Arnette, the passenger, brought action against American Airlines, claiming that one of its gate agents improperly accessed his personal information and harassed him.

Issue

Did the trial court abuse its discretion by compelling the deposition of a high-level corporate official without requiring the passenger to meet the standards for deposing an apex executive?

Did the trial court abuse its discretion by compelling the deposition of a high-level corporate official without requiring the passenger to meet the standards for deposing an apex executive?

Rule

When seeking to depose a corporate president or high-level official, the party must show that the official has unique or superior personal knowledge of discoverable information. If this showing is not made, the trial court must grant a protective order and require the party to attempt less intrusive methods of discovery first.

When seeking to depose a corporate president or high-level official, the party must show that the official has unique or superior personal knowledge of discoverable information.

Analysis

The Supreme Court found that Dr. Arnette did not meet the necessary standards for deposing Eberwein, as he failed to demonstrate that she had unique or superior knowledge relevant to the case. The court noted that Arnette did not attempt less intrusive means of discovery and that Eberwein's affidavit indicated she had no personal knowledge of the relevant facts. Therefore, the trial court's order compelling her deposition was an abuse of discretion.

The Supreme Court found that Dr. Arnette did not meet the necessary standards for deposing Eberwein, as he failed to demonstrate that she had unique or superior knowledge relevant to the case.

Conclusion

The Supreme Court conditionally granted American Airlines' petition for writ of mandamus, stating that the trial court must vacate its order compelling Eberwein's deposition.

The Supreme Court conditionally granted American Airlines' petition for writ of mandamus, stating that the trial court must vacate its order compelling Eberwein's deposition.

Who won?

American Airlines prevailed in the case because the Supreme Court found that the trial court abused its discretion in compelling the deposition without requiring compliance with the apex deposition standards.

American Airlines prevailed in the case because the Supreme Court found that the trial court abused its discretion in compelling the deposition without requiring compliance with the apex deposition standards.

You must be