in Re Christus Health Southeast Texas D/B/A Christus St. Elizabeth Hospital, 399 S.W.3d 343

Christus Health Southeast Texas d/b/a Christus St. Elizabeth Hospital sought mandamus relief to compel discovery responses; trial court denied two requests.
Lowes filed a health care liability suit for wrongful death and survival damages related to Arthur Lowe’s June 30, 2009 cardiac catheterization and subsequent death.
Contested requests: (i) purchases and calls by Melissa Lowe and Laura Singletary on June 30, 2009, and (ii) postings about Arthur or his death on social media.
Trial court’s order specified it applied only to the two disputed requests after an unrecorded hearing.
Court held the discovery scope must be reasonably tailored; the first request spanned a 24-hour period including pre-event times and was not narrowly tailored; the second request for social media posts was unbounded in time and thus overbroad.
Petition denied; the trial court did not abuse its discretion in denying the two discovery requests.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court err by denying production of purchase/call records for Melissa and Laura?	Christus contends records needed to time-events.	Lowes argued records are irrelevant or overly burdensome.	No; the request was overly broad and not narrowly tailored.
Did the trial court err by denying social media postings about Arthur or his death?	Posts relevant to the case could be discovered.	Unbounded time frame and privacy concerns justify denial.	No; the time limit was absent, making the request overbroad.

Ford Motor Co. v. Castillo, 279 S.W.3d 656 (Tex. 2009) (limits on discovery; disposition on merits principle; scope of discovery broader but needs tailoring)
CSX Corp., 124 S.W.3d 149 (Tex. 2003) (discovery scope is broad but must be reasonably tailored; abuse for overbreadth)
In re TIG Ins. Co., 172 S.W.3d 160 (Tex. App.—Beaumont 2005) (burden on proponent to show documents fall within Rule 192.3)
In re Deere & Co., 299 S.W.3d 819 (Tex. 2009) (time-limited discovery; overbroad requests error when no time limit)
In re Am. Optical Corp., 988 S.W.2d 711 (Tex. 1998) (overly broad discovery orders spanning long time periods)
In re Dana Corp., 138 S.W.3d 298 (Tex. 2004) (mandamus relief when trial court abuses discovery process)
In re Le, 335 S.W.3d 808 (Tex. App.—Houston [14th Dist.] 2011) (record sufficient for mandamus review; no need for additional records)