Stephen Michael West v. Derrick D. Schofield, 460 S.W.3d 113

2013 Tennessee Department of Correction adopted a one-drug pentobarbital lethal injection protocol for executions.
Several death-row inmates filed a declaratory judgment action challenging the Protocol as unconstitutional under the U.S. and Tennessee constitutions.
Plaintiffs sought discovery identifying John Doe execution participants and related personnel, despite confidentiality claims.
Trial court granted discovery and ordered disclosure under a protective order; Court of Appeals affirmed.
This Court reverses the Court of Appeals and trial court, remanding for further proceedings with timelines, holding John Doe identities are not relevant to the facial challenge and are improperly compelled discovery.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether John Doe identities are privileged from discovery.	West argues confidentiality statutes and public policy protect identities.	State contends common-law privilege or statutory protection bars disclosure.	No, not a required privilege; reach on privilege foreclosed in light of relevance.
Whether John Doe identities are relevant to the facial challenge to the Protocol.	Plaintiffs contend identities could affect scrutiny of qualifications and process.	Defendants argue identities bear on execution alongside the protocol's operation.	Identities are not relevant to the facial validity of the Protocol.
Whether discovery balancing favors disclosure given privacy and safety concerns.	Plaintiffs claim need for verification justifies disclosure.	State argues privacy, safety, and secrecy weigh against disclosure.	Trial court erred by not adequately balancing interests; even so, identities are not discoverable for facial challenge.
Whether claims as-applied challenges are justiciable and ripe for discovery.	Inmates claim possible future abuses could render Protocol unconstitutional as applied.	Claims are speculative and future-oriented; not ripe.	As-applied challenges were not ripe or adequately pleaded in the declaratory action.

Baze v. Rees, 553 U.S. 35 (U.S. 2008) (Eighth Amendment standards for capital punishment protocols)
State v. Banks, 271 S.W.3d 90 (Tenn. 2008) (abuse of discretion standard for trial court decisions)
Wellons v. Comm’r, Ga. Dep’t of Corr., 754 F.3d 1260 (11th Cir. 2014) (No right to know execution drug sources; confidentiality balanced against access)
Lombardi, Inc. v. Smithfield, 11 A.3d 1180 (Del. 1989) (illustrative on discovery privileges (as cited in context))
Hill v. State, 758 S.E.2d 805 (Ga. 2012) (execution-identity confidentiality upheld under state law)
In re Baby, 447 S.W.3d 807 (Tenn. 2014) (legislation history informing public policy on surrogacy/privilege)
Parks v. Alexander, 608 S.W.2d 881 (Tenn.Ct.App. 1980) (Declaratory judgments act limitations; justiciability concerns)
State v. Garrett, 331 S.W.3d 392 (Tenn. 2011) (abuse of discretion; factors for discovery balancing)
Harbison v. Little, 511 F.Supp.2d 872 (M.D. Tenn. 2007) (anonymity for execution witnesses respected)