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Keywords

discoveryappealtrialtrusttrade secretantitrust

trialmotiontrade secret

Related Cases

In re Waste Management of Texas, Inc., 392 S.W.3d 861, 2013-1 Trade Cases P 78,235

Facts

The antitrust action was initiated by Josh Bray d/b/a Sanitation Solutions against Waste Management of Texas, Inc. in Lamar County. In 2009, Waste Management produced various internal business records in PDF format, excluding metadata, following a court order. In 2012, the trial court ordered Waste Management to produce similar information in its native electronic format with all metadata. Waste Management petitioned for mandamus relief, arguing that the order required disclosure of trade secrets and was overly burdensome.

On March 5, 2009, the trial court signed an order granting Bray's motion to compel and recognizing the parties' agreement 'that metadata shall be preserved but need not be produced at this time.'

Issue

Did the trial court abuse its discretion by ordering Waste Management to produce electronic records in their native format with metadata, and did Waste Management establish that the information contained trade secrets or that the order was unduly burdensome?

Waste Management argues that the order requires production of data outside the relevant geographic area and is thus an overbroad 'fishing expedition.'

Rule

Mandamus relief is appropriate when a party shows a clear abuse of discretion or a violation of a legal duty, and there is no adequate remedy at law. A party resisting discovery must establish that the information is a trade secret, after which the burden shifts to the requesting party to show that the information is necessary for a fair adjudication.

Mandamus issues only when the mandamus record establishes (1) a clear abuse of discretion or the violation of a duty imposed by law and (2) the absence of a clear and adequate remedy at law.

Analysis

The court found that Waste Management did not provide sufficient evidence to establish that the requested information contained trade secrets. The court noted that the burden to prove the necessity of the information for fair adjudication did not shift to Bray because Waste Management failed to demonstrate that the information was indeed a trade secret. Additionally, the court determined that the trial court's order was not overly broad or unduly burdensome, as the requests were specific and relevant to the case.

The court found that Waste Management did not provide sufficient evidence to establish that the requested information contained trade secrets.

Conclusion

The Court of Appeals denied Waste Management's petition for mandamus relief, affirming the trial court's order requiring the production of electronic records in their native format with metadata.

Mandamus relief denied.

Who won?

Josh Bray d/b/a Sanitation Solutions prevailed in the case because the court found that Waste Management did not meet its burden to show that the requested information contained trade secrets or that the discovery order was unduly burdensome.

Waste Management has not shown that the matters to be disclosed include trade secrets.

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