George Flores, Relator v. the Fourth Court of Appeals, Respondent

Summary

The Texas Supreme Court held that the trial court did not abuse its discretion in ordering production of the pre‑hearing investigative report because the report was not prepared in anticipation of litigation and litigation did not commence until a suit was filed in district court; therefore the writ of mandamus was conditionally granted. Justice Gonzalez dissented, arguing that filing a claim with the Industrial Accident Board should start litigation and the report is privileged.