In re Graco Children's Products, Inc

In In re Graco Children's Products, Inc., 210 S.W.3d 598 (Tex. 2006) the plaintiff sued Graco, alleging that defects in a baby car seat's five-point harness caused the death of her son. See id. at 600. Shortly before the trial setting, Graco paid a substantial civil penalty to the Consumer Products Safety for failing to report defects in more than a dozen products, including high chairs, swings, strollers, toddler beds, and infant carriers. See id. None of the listed defects involved five-point harnesses. See id. The plaintiff nonetheless sought production of twenty categories of documents "including anything that mentioned or referred to" any of the defects or products. See id. Graco objected that the civil penalty had nothing to do with the carrier or defect at issue, and that production would involve 20,000 pages of documents located in other states. See id. The Supreme Court of Texas found the requests overly broad as a matter of law because there was "no apparent connection between the alleged defect and the discovery ordered." Id. at 601.