In City of Lubbock v. Cornyn, 993 S.W.2d 461, 465 (Tex. App.--Austin 1999, no pet.), the Court affirmed a judgment that accident reports must be disclosed to requestors despite a statute apparently intended to limit disclosure to persons involved in the accident. 993 S.W.2d at 463.
The reports were confidential, but available to persons who knew two of the three key facts: the date of the accident, the name of a person involved in the accident, and the specific location of the accident. Id. at 464.
Persons not otherwise aware of these key facts, however, requested police dispatch logs to learn the key facts and then used the key facts to request the accident reports. Id.
The City of Lubbock sought to deny release of the accident reports to persons who did not know the key facts before requesting the dispatch logs. Id. at 464-65.
The Court held that the City had no discretion to withhold the accident reports to persons with the key facts regardless of how they learned those facts. Id. at 465.