in Re: Espiridion Guzman
Relator Espiridion Guzman, who was involved in a fatal truck collision, settled a wrongful death and survivor benefits suit with the heirs of the deceased. Subsequently, Haas Anderson and Warning Lites, Inc., co-defendants in the original suit, sought contribution and indemnity from Guzman and his employer, Bicentennial Trucking, Inc., alleging negligent entrustment due to Guzman's incompetence. To support their claims, Haas Anderson requested that Guzman sign authorizations for the release of his drivers history, medical history, employment history, and worker's compensation claims. The trial court ordered Guzman to execute these authorizations, prompting Guzman to file a Petition for Writ of Mandamus. Guzman argued that the court lacked the authority under the Texas Rules of Civil Procedure to compel him to create documents (the signed authorizations) that did not previously exist. The Court of Appeals agreed, holding that Rules 196 and 205 do not authorize a court to order the creation of such authorizations. Consequently, the writ of mandamus was conditionally granted, instructing the trial court to vacate its order compelling Guzman to sign the authorizations.