In Re State, 325 S.W.3d 848

In November 2009, the State sought to condemn LeGuins' property for IH-35 expansion in an eminent domain proceeding in the trial court.
LeGuins requested disclosure of appraisals, work files, construction plans, and other documents related to value and market effects prior to the commissioners' hearing; the State objected.
The trial court granted the LeGuins' motion to compel disclosure; the State filed a petition for writ of mandamus seeking to vacate that order.
Eminent domain in Texas proceeds in two phases: an administrative phase with three special commissioners and a de novo trial if objections are filed, intended to be quick and inexpensive.
The issue centers on whether Texas Property Code 21.024 requires the State's disclosure of the requested information during the administrative phase, given the State, Commission, and Department's status as governmental entities.
The Texas Court of Appeals conditionally grants mandamus, concluding 21.024 does not apply to the State, Commission, or Department and that the trial court abused its discretion by ordering disclosure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does 21.024 apply to the State entities in the administrative phase?	LeGuins: 21.024 applies to critical infrastructure entities.	State: 21.024 does not apply to governmental entities like the State, Commission, or Department.	No; 21.024 does not apply to the State entities.
Is mandamus proper where an adequate remedy by appeal exists?	LeGuins: mandamus unnecessary because adequate remedy by appeal via de novo trial exists.	State: no adequate remedy since immediate disclosure affects a substantial right to a quick administrative hearing.	No adequate remedy by appeal exists; mandamus proper.
Did the trial court abuse its discretion by ordering disclosure under 21.024?	LeGuins: court should compel disclosure to aid valuation.	State: disclosure mandated by 21.024 is inapplicable to these governmental entities; court erred governing law.	Yes; trial court abused its discretion.
Are the State, Department, and Commission properly outside the scope of 21.024 due to sovereign/inherent eminent domain power?	LeGuins assert potential application via broad critical infrastructure framing.	State: inherent sovereign power and statutory structure place these entities outside 21.024.	Yes; these entities are not governed by 21.024.

Gulf Energy Pipeline Co. v. Garcia, 884 S.W.2d 821 (Tex. App.-San Antonio 1994) (eminent domain rapid, fair administrative phase purpose and structure)
In re State, 85 S.W.3d 871 (Tex. App.-Tyler 2002) (administrative phase aims for quick resolution; trial de novo considerations)
PR Investments & Specialty Retailers, Inc. v. State, 251 S.W.3d 472 (Tex. 2008) (eminent domain proceedings and expedited resolution notions)
Blasingame v. Krueger, 800 S.W.2d 391 (Tex.App.-Houston [14th Dist.] 1990) (adequacy of remedy-by-appeal in de novo context)
In re Jorden, 249 S.W.3d 416 (Tex. 2008) (presuit depositions and discovery timing comparisons in mandamus context)
In re Bustamante, 104 S.W.3d 704 (Tex.App.-El Paso 2003) (abuse of discretion standard in statutory interpretation)
City of Dallas v. Abbott, 304 S.W.3d 380 (Tex. 2010) (statutory interpretation and limits on governmental entities)