Denton v. Texas Department of Public Safety Officers Ass'n
Lane Denton sued the Texas Department of Public Safety Officers Association (DPSOA) and other appellees for wrongful termination, breach of contract, intentional infliction of emotional distress, violation of privacy, and tortious interference with business. Denton invoked his Fifth Amendment privilege against self-incrimination during discovery due to a pending criminal indictment for misappropriation of DPSOA funds. The trial court denied his requests for abatement and a protective order, subsequently dismissing his civil suit for non-compliance with discovery. The appellate court reversed the trial court's judgment, finding that Denton did not waive his privilege by 'offensive use' under the *Republic Insurance Co. v. Davis* test. The court also concluded that dismissal was an excessive sanction given Denton's legitimate assertion of his constitutional rights, and remanded the case for further proceedings.