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Click here for the full text of this decision FACTS:Patricia Galnares was driving on Interstate 55 near McComb, Miss., when she veered off the road, overcorrected and caused her Jeep Liberty to roll over. She and her 13-year-old brother Antonio suffered no permanent injury as they were wearing seatbelts. But her newborn 5-week-old son Michael was found on the front seat floorboard with fatal head injuries. Galnares sued Graco Children’s Products Inc. in Hidalgo County, alleging that defects in the harness clip of the baby’s car seat failed to restrain him in the rollover. Graco’s defense is that immediately after the accident investigating officers found the harness unbuckled and that Antonio reported at the scene and later at the hospital that the baby was sitting unrestrained on the front seat while Galnares fed him. Two weeks before trial in April 2005, the Consumer Products Safety Commission announced a provisional settlement with Graco imposing a $4 million civil penalty � the largest in the agency’s history � for failing to report defects in more than a dozen products, including highchairs, swings, strollers, toddler beds and infant carriers. The announcement listed defects such as swing trays that came unlocked, infant carrier handles that broke, highchair legs that failed and bed slats that could entangle an infant’s limbs. None of the products had five-point harnesses. None mentioned defective harness buckles. While an infant carrier was included, the defect cited was a carrying handle used only when walking, not driving. Nevertheless, Galnares’ attorneys immediately served a notice of deposition and a Fourth Request for Production on Graco, seeking 20 categories of documents including anything that mentioned or referred to any of the defects, products, complaints or people who might have been involved with those products or the investigation. Graco objected, pointing out that the announcement had nothing to do with the carrier or defect alleged in Galnares’s suit and that producing the documents would involve about 20,000 pages of documents located in Pennsylvania, Ohio and Illinois. After two hearings, the trial court ordered Graco to produce two representatives for deposition as well as all the documents Galnares requested. The 13th Court of Appeals denied relief. HOLDING:The petition for a writ of mandamus is granted. The court cited prior instances when it granted mandamus in several product-liability cases when a discovery order covered products the plaintiff never used. “In this case,” the court stated, “there is again no apparent connection between the alleged defect and the discovery ordered.” As Galnares’ discovery requests were not reasonably tailored to the relevant product defect, they were impermissibly overbroad, the court stated. The court stated that while a corporate defendant’s “state of mind” about a particular product may be discoverable, the court has rejected attempts to extend that inquiry to every product it ever made. The court stated: “Any attorney would be interested in a record-breaking sanction against an adversary in an upcoming trial. But with no evidence that a defect was involved similar to the one alleged in this case, it was a blind alley. Evidence about different products and dissimilar accidents has long been inadmissible, as it generally proves nothing while distracting attention from the accident at hand.” OPINION:Per curiam.

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