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In re Christianson Air Conditioning & Plumbing, LLC

plastic water pipes

Court: Supreme Court of Texas

Docket: 20-0384

Opinion Date: February 4, 2022

Judge: Busby

Areas of Law: Personal Injury, Products Liability

This case law update is brought to you by Freeway Law auto accident and personal injury lawyers in Orange County. The following is not one of our cases, but it is of some significance, and we thought we should share it with our readers for informational purposes. The information above is for informational purposes only and not to be construed as legal advice.

The Supreme Court held that, at least where specific jurisdiction is asserted, Tex. R. Civ. P. 120a discovery need not relate exclusively to jurisdictional issues without touching on merits issues.

The parties in this suit concerning water leaks from plastic pipe made of cross-linked polyethylene failed to agree on the scope of two corporate representative depositions, and so the trial court granted a motion to compel the depositions on a list of thirty topics proposed by Plaintiffs. The nonresident defendant sought mandamus relief, which the court of appeals granted, concluding that the trial court erred in compelling discovery on topics that touched both jurisdictional and merits issues. The Supreme Court directed the court of appeals to vacate its mandamus order, holding (1) the trial court did not abuse its discretion merely by compelling discovery on jurisdictional topics; (2) the standard for trial courts to apply is that the information sought must be essential to prove at least one part of the plaintiff’s theory of personal jurisdiction; and (3) general principles that limit the scope of discovery apply equally to jurisdictional discovery.

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