Nephrology Leaders and Associates and M. Atiq Dada, MD v. American Renal Associates LLC, 573 S.W.3d 912

Nephrology Leaders and Associates and Dr. M. Atiq Dada sued a law firm and subpoenaed documents from third‑party American Renal Associates (American Renal) in that underlying breach‑of‑fiduciary‑duty litigation.
American Renal filed a protective‑order motion asserting Nephrology had released its discovery rights via two release agreements (filed in camera) and simultaneously moved to temporarily and permanently seal those releases under Tex. R. Civ. P. 76a.
The trial court scheduled a submission hearing on American Renal’s protective motion; it sua sponte added the motion to seal to the same hearing date and thereafter signed a temporary sealing order under Rule 76a.
Nephrology appealed the temporary sealing order under Rule 76a(8), arguing (1) the court abused its discretion by setting the motion for a hearing sua sponte and (2) the evidence did not support sealing.
The Court of Appeals instead addressed subject‑matter jurisdiction/standing and held Nephrology lacked constitutional standing to appeal because it failed to show a concrete, redressable injury from the sealing order.
Because Rule 76a(8)’s appellate grant cannot expand constitutional standing requirements, the court dismissed the appeal for want of jurisdiction without reaching Nephrology’s other arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nephrology has standing to appeal the Rule 76a sealing order without proving injury	Rule 76a(8) makes any party who participated in the hearing eligible to appeal; injury proof is immaterial	Rule 76a(8) does not relieve appellant of constitutional standing requirements (injury and redressability)	Nephrology lacks standing; appeal dismissed for want of subject‑matter jurisdiction
Whether the trial court abused its discretion by sua sponte setting the sealing motion for hearing	Trial court abused discretion in adding sealing motion and in issuing sealing order	Court procedure was proper; sealing warranted on record	Not reached on the merits because appeal dismissed for lack of standing

Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440 (Tex. 1993) (standing is a constitutional prerequisite to suit)
Heckman v. Williamson County, 369 S.W.3d 137 (Tex. 2012) (no jurisdiction over claims by parties lacking standing)
Fin. Comm’n of Tex. v. Norwood, 418 S.W.3d 566 (Tex. 2013) (statutes cannot enlarge constitutional jurisdiction; standing requirement applies)
McAllen Med. Ctr., Inc. v. Cortez, 66 S.W.3d 227 (Tex. 2001) (statutory appellate rights do not supplant constitutional standing)
Torrington Co. v. Stutzman, 46 S.W.3d 829 (Tex. 2000) (appellant may not complain of errors that do not injuriously affect it)
In re Allcat Claims Serv., L.P., 356 S.W.3d 455 (Tex. 2011) (courts restrict statutory grants to the limits of constitutional jurisdiction)