Texaco, Inc. v. Sanderson

In Texaco, Inc. v. Sanderson, 898 S.W.2d 813, 815, 38 Tex. Sup. Ct. J. 672 (Tex. 1995), the plaintiffs claimed injurious workplace exposure to benzene and requested all safety and toxicology documents written by the corporate safety director, including those documents regarding other employees' exposure and plants where the plaintiffs never worked. Texaco, 898 S.W.2d at 814. The request also extended into a time period during which the plaintiffs did not work with the company. Id. The Court held the request was overbroad, because it was "not merely an impermissible fishing expedition; it was an effort to dredge the lake in hopes of finding a fish." Id. at 815. A central consideration in determining overbreadth is whether the request could have been more narrowly tailored to avoid including tenuous information and still obtain the necessary, pertinent information. See American Optical, 988 S.W.2d at 713. A request to identify all safety employees who worked for Relators over a 30-year period, even though Ward never worked for Relators or for their parent company for that length of time, qualifies as the kind of "fishing expedition" this Court has repeatedly struck down. See, e.g., Texaco, 898 S.W.2d at 815.