City of San Antonio v. Spears
This is an original mandamus proceeding addressing whether an investigative report in a worker's compensation case, prepared after a claim but before appeal to district court, is privileged. George Flores, plaintiff in a worker's compensation case against the self-insured City of San Antonio (relator), sought discovery of such a report. Relator objected, asserting privilege. Judge Carolyn Spears, the respondent, ordered the production of a "Pre-Hearing Conference Preliminary Report." The relator sought a writ of mandamus to compel Judge Spears to vacate her order. The court held that "litigation" encompasses proceedings before the Industrial Accident Board, and therefore the pre-hearing report is privileged. Consequently, the writ of mandamus was conditionally granted.