in Re Rsr Corporation and Quemetco Metals Limited, Inc., 568 S.W.3d 663

RSR sued Inppamet (and affiliate) over breach of contract and trade-secret misappropriation; dispute included allegations that RSR’s counsel received privileged/confidential information from a former Inppamet employee.
Inppamet initially moved to disqualify RSR’s counsel relying on Meador’s fact-intensive factors and Contico but later abandoned Meador and argued the presumptions from In re American Home Products should control.
A discovery special master and the trial court considered the matter; the trial court applied American Home Products and disqualified RSR’s counsel.
This Court granted mandamus in 2015 (In re RSR) holding American Home Products’ presumptions apply only to side-switching legal staff and that Meador governs when privileged information comes from non-law-firm fact witnesses, remanding without deciding Meador’s merits.
After this Court’s opinion, Inppamet sought to renew disqualification under Meador and to reopen discovery; the trial court denied reconsideration as untimely, dilatory, and waived; the court of appeals ordered the trial court to revisit the Meador analysis.
The Supreme Court reversed the court of appeals, holding the trial court did not clearly abuse its discretion in treating Inppamet’s Meador-based efforts as waived/dilatory and reinstated the trial-court denial to avoid further delay and tactical use of disqualification.

Issue	Plaintiff's Argument (Inppamet)	Defendant's Argument (RSR)	Held
Proper standard for disqualification	American Home Products presumptions control	Meador factors govern when privileged info came from non-law-firm fact witness	Court: Meador governs in those circumstances; AHP presumptions limited to side-switching legal staff (previously decided in In re RSR)
Whether Inppamet waived or untimely in seeking Meador relief after previously abandoning it	Reassertion is timely after this Court’s opinion; discovery can be reopened	Inppamet intentionally abandoned Meador earlier; failure to pursue constitutes waiver/dilatoriness	Court: Trial court reasonably found waiver/dilatory conduct; no clear abuse of discretion
Whether special master’s discovery denial bars merits reconsideration	Discovery denial unrelated to merits; court should consider Meador now	Discovery was previously forgone; reopening now would unduly delay trial	Court: Reopening discovery and relitigating would be dilatory and unjustifiably delay the decade-old case
Whether mandamus by court of appeals was appropriate to force merits reconsideration	Mandamus necessary because trial court refused to apply Meador after this Court’s opinion	Trial court’s exercise of discretion insulated; appellate mandamus inappropriate	Court: Court of appeals erred; vacate its mandamus order and reinstate trial court’s denial

In re American Home Products Corp., 985 S.W.2d 68 (Tex. 1998) (establishes presumptions for disqualification when legal staff switch sides)
In re Meador, 968 S.W.2d 346 (Tex. 1998) (articulates six-factor, fact-intensive test for disqualification where privileged info came from non-law-firm fact witnesses)
In re RSR Corp., 475 S.W.3d 775 (Tex. 2015) (this Court held Meador—not AHP—governs here and remanded without resolving Meador merits)
In re EPIC Holdings, Inc., 985 S.W.2d 41 (Tex. 1998) (addresses waiver and revival of abandoned disqualification motions under changed circumstances)
In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (mandamus availability turns on adequacy of appellate remedy; delay can make appellate relief inadequate)