attorney work product privilege (Texas) · Go Syfert
← Texas issues

attorney work product privilege in Texas

27 Texas opinions name it 2 courts 1990–2025 6 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (11)

CaseFollowedCited
Occidental Chemical Corp. v. Banalesgreen
tex · 1995 · cited in 3 Texas opinions naming this issue, 2006–2025
2 sentences

2006Corp. v. Banales, 907 S.W.2d 488, 490 (Tex.1995, orig. proceeding) ("The attorney work product privilege protects two related but different concepts.

2006Corp. v. Banales, 907 S.W.2d 488, 490 (Tex.1995, orig. proceeding) ("The attorney work product privilege protects two related but different concepts.

33
Walker v. Packergreen
tex · 1992 · cited in 3 Texas opinions naming this issue, 2005–2006
2 sentences

2006Walker v. Packer, 827 S.W.2d 833, 840 (Tex. 1992). 4 By their first issue, Nelson and Johnson contend the trial court abused its discretion in issuing sanctions against them for ”discovery abuse” where they invoked the attorney work product privilege at Nelson’s deposition by Albertson’s counsel.

2005In Walker v. Packer , 827 S.W.2d 833 (Tex. 1992)(orig. proceeding), with regard to a claim of privilege, the Texas Supreme Court stated: [A] party will not have an adequate remedy by appeal when the appellate court would not be able to cure the trial court's discovery error.

13
in Re National Lloyds Insurance Company, Wardlaw Claims Service, Inc. and Ideal Adjusting, Inc.green
tex · 2017 · cited in 2 Texas opinions naming this issue, 2023–2025
2 sentences

2025Co., 532 S.W.3d 794, 806 (Tex. 2017) for the proposition that billing records fall within the “zone of work-product protection.” 9 Moreover, as applicable to both provisions, the trial court reserved the power to, “from time to time, enter orders and protective orders necessary to do justice between the parties.” Where the trial court has expressly left the door open for the further resolution of contested issues, the challenged provisions fail to dispose of all remaining claims before the court, do not constitute final orders, and are not susceptible of appellate review.

2023Finally, the Burciagas have requested “[a]ll bills for services rendered sent by Judy Osborn to Hyde Park Baptist Church during the period June 1, 2020 to the present.” The Texas Supreme Court has held that “compelling en masse production of a party’s billing records invades the attorney work-product privilege.” In re National Lloyds, 532 S.W.3d at 820 .

12
Pope v. Stategreen
texcrimapp · 2006 · cited in 2 Texas opinions naming this issue, 2015–2021
2 sentences

2021App. 2006) (“The attorney work-product doctrine, while not a true evidentiary privilege, belongs to and protects the attorney.”); see also United States v. Nobles, 422 U.S. 225 238 , 95 S.Ct. 2160 , 45 L.Ed.2d 141 (1975) (noting “[a]t its core, the work-product doctrine shelters the mental processes of the attorney, providing a privileged area within which [the attorney] can analyze and prepare his client’s case”). 16 Pope, 207 S.W.3d at 357–58 (“[The work-product doctrine’s] purpose is to stimulate the production of information for trials, and it rewards an attorney’s creative efforts by givi

2021App. 2006) (“The attorney work-product doctrine, while not a true evidentiary privilege, belongs to and protects the attorney.”); see also United States v. Nobles, 422 U.S. 225 238 , 95 S.Ct. 2160 , 45 L.Ed.2d 141 (1975) (noting “[a]t its core, the work-product doctrine shelters the mental processes of the attorney, providing a privileged area within which [the attorney] can analyze and prepare his client’s case”). 16 Pope, 207 S.W.3d at 357–58 (“[The work-product doctrine’s] purpose is to stimulate the production of information for trials, and it rewards an attorney’s creative efforts by givi

12
in Re: Fisher & Paykel Appliances, Inc.green
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See In re Fisher & Paykel Appliances, Inc., 420 S.W.3d 842, 849 (Tex. App. – Dallas 2014, no pet.) (“In ordering the production of the documents, the trial court necessarily reached and overruled the attorney work product privilege objection.”). 14 Nevertheless, on November 4, 2024, RPI Okonkwo granted the Relator’s Motion to Compel.

11
Lewis v. Wittiggreen
texapp · 1994 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024Id. at 806, n. 43 (citing Lewis v. Wittig, 877 S.W.2d 52, 57 (Tex. App.—Houston [14th Dist.] 1994, orig. proceeding)).

11
United States v. Noblesgreen
scotus · 1975 · cited in 1 Texas opinions naming this issue, 2021–2021
2 sentences

2021App. 2006) (“The attorney work-product doctrine, while not a true evidentiary privilege, belongs to and protects the attorney.”); see also United States v. Nobles, 422 U.S. 225 238 , 95 S.Ct. 2160 , 45 L.Ed.2d 141 (1975) (noting “[a]t its core, the work-product doctrine shelters the mental processes of the attorney, providing a privileged area within which [the attorney] can analyze and prepare his client’s case”). 16 Pope, 207 S.W.3d at 357–58 (“[The work-product doctrine’s] purpose is to stimulate the production of information for trials, and it rewards an attorney’s creative efforts by givi

2021App. 2006) (“The attorney work-product doctrine, while not a true evidentiary privilege, belongs to and protects the attorney.”); see also United States v. Nobles, 422 U.S. 225 238 , 95 S.Ct. 2160 , 45 L.Ed.2d 141 (1975) (noting “[a]t its core, the work-product doctrine shelters the mental processes of the attorney, providing a privileged area within which [the attorney] can analyze and prepare his client’s case”). 16 Pope, 207 S.W.3d at 357–58 (“[The work-product doctrine’s] purpose is to stimulate the production of information for trials, and it rewards an attorney’s creative efforts by givi

11
City of Garland v. Dallas Morning Newsgreen
tex · 2000 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018See Dallas Morning News, 22 S.W.3d at 361 (observing that section 552.111 exception encompasses common law deliberative process privilege); Tex. Att’y Gen.

11
Cameron v. Stategreen
texcrimapp · 2007 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Cameron v. State, 241 S.W.3d 15, 19 (Tex. Crim.

11
In Re Qwest Communications International Inc.green
ca10 · 2006 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014In re Columbia/HCA Healthcare Corp. Billing Practices Litig., 293 F.3d 289 , 306-07 (6th Cir.2002) (attorney-client and work product privileges were not intended “to protect conversations between the client and the government, i.e., an adverse party”); In re Qwest Commc’ns Int’l Inc., 450 F.3d 1179, 1195 (10th Cir. 2006) (“Moreover, the purpose of the work-product doctrine is to enable counsel to prepare a case in privacy.

11
Toyota Motor Sales, U.S.A., Inc. v. Heardgreen
texapp · 1989 · cited in 1 Texas opinions naming this issue, 1990–1990
1 sentence

1990Toyota Motor Sales, U.S.A., Inc. v. Heard, 774 S.W.2d 316, 317 (Tex.App.— Houston [14th Dist.] 1989, orig. proceeding); Evans v. State Farm Mut.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (14)

CaseCitedYears
Axelson, Inc. v. McIlhany green
tex · 1990
2 sentences

2021Because the character of the evidence is at least in dispute, we cannot say there is one clear rational decision 21 See Axelson, Inc. v. McIlhany, 798 S.W.2d 550 , 554 n.8 (Tex. 1990, orig. proceeding) (noting that the attorney work product privilege “protects only the mental impressions, opinions, and conclusions of the lawyer and not the facts.) (emphasis added). 22 J.

1996Axelson v. McIlhany, 798 S.W.2d 550 , 554 n. 8 (Tex. 1990).

21996–2021
Marshall v. Hall green
texapp · 1997
2 sentences

2014Id. at 183 .

2014Id. at 183 .

22014–2014
Washington v. State green
texcrimapp · 1993
1 sentence

2019Washington v. State, 856 S.W.2d 184 , 189–90 (Tex. Crim.

12019–2019
Maine v. Moulton green
scotus · 1985
1 sentence

2019The State’s “affirmative obligation not to act in a manner that circumvents and thereby dilutes the protection afforded by the right to counsel,” Id. at 170–71—and the concomitant duty to refrain from reviewing the records—still applies.

12019–2019
In Re Skiles green
texapp · 2003
1 sentence

2015LAW. 20, 21 (1996) ("The joint defense-common interest privilege must rest upon an underlying privilege such as the attorney-client privilege or the attorney work product privilege."). 78 Id. 79See generally Exhibits P and Q; respectively.

12015–2015
Loftin v. Martin green
tex · 1989
2 sentences

2015RESPONSE: Robinson objects to the immediately preceding request to the extent that it is overly broad; vague; unduly burdensome and expensive to answer as presented; unlimited in scope; not reasonably limited in time; duplicative of request number 13 of Plaintiffs’ first set of requests for production; constitutes a mere “fishing expedition” prohibited by the Texas Supreme Court in Lofton v. Martin, 776 S.W.2d 145 (Tex. 1989); seeks information protected by the attorney-client privilege; seeks information protected by the attorney-work product privilege; seeks information not within the actual

2015RESPONSE: Robinson objects to the immediately preceding request to the extent that it is overly broad; vague; unduly burdensome and expensive to answer as presented; unlimited in scope; not reasonably limited in time; constitutes a mere “fishing expedition” prohibited by the Texas Supreme Court in Lofton v. Martin, 776 S.W.2d 145 (Tex. 1989); seeks information protected by the attorney-client privilege; seeks information protected by the attorney-work product privilege; seeks information not within the actual or constructive control of this party; is not reasonably calculated to lead to the di

12015–2015
In Re Columbia/Hca Healthcare Corporation Billing Practices Litigation green
ca6 · 2002
1 sentence

2014In re Columbia/HCA Healthcare Corp. Billing Practices Litig., 293 F.3d 289 , 306-07 (6th Cir.2002) (attorney-client and work product privileges were not intended “to protect conversations between the client and the government, i.e., an adverse party”); In re Qwest Commc’ns Int’l Inc., 450 F.3d 1179, 1195 (10th Cir. 2006) (“Moreover, the purpose of the work-product doctrine is to enable counsel to prepare a case in privacy.

12014–2014
United States v. Morrison green
scotus · 1981
1 sentence

2010After a review of the transcripts of the telephone calls and an in camera review of the Hunt County District Attorney‘s Office‘s file, Judge Biard concluded the Hunt County 35 After finding the Sixth Amendment violation, the trial court properly followed the United States Supreme Court directive to ―identify and then neutralize the taint by tailoring relief appropriate in the circumstances to assure the defendant effective assistance of counsel and a fair trial.‖ Morrison, 449 U.S. at 365 . 28 District Attorney‘s Office did not obtain any useful information from the recordings and denied the d

12010–2010
In Re Exxon Corp. green
texapp · 2006
1 sentence

2009Relators rely on In re Exxon Corporation , 208 S.W.3d 70 (Tex. App. C Beaumont 2006, orig. proceeding), to support this contention.

12009–2009
Leede Oil & Gas, Inc. v. McCorkle green
texapp · 1990
1 sentence

1997Id.

11997–1997
Republic Insurance Co. v. Davis green
tex · 1993
1 sentence

1994In the second sentence of the paragraph of interest, the Court said: “Our decision today does not prevent a party from requesting specific documents or categories of documents relevant to issues in a pending case, even though some or all of the documents may be contained in an attorney’s files.” This is consistent with the Court’s earlier statement that “a document is not privileged simply because it is contained in an attorney’s files.” Id. at 460 .

11994–1994
National Union Fire Insurance Co. v. Valdez green
tex · 1993
1 sentence

1994Id.

11994–1994
Owens v. Wallace green
texapp · 1992
2 sentences

1994Tex.R.Civ.P. 166b(3); Owens, 821 S.W.2d at 747-48 .

1994Tex.R.Civ.P. 166b(3); Owens, 821 S.W.2d at 747-48 .

11994–1994
Owens-Corning Fiberglas Corp. v. Caldwell green
tex · 1991
1 sentence

1992Owens-Corning Fiberglas Corp. v. Caldwell, 818 S.W.2d 749 (Tex.1991).

11992–1992

Where else courts name it

CA 72 (1979–2026) PA 37 (1973–2025) NY 31 (1984–2025) TX 27 (1990–2025) WA 15 (1981–2019) OH 13 (2006–2025) NJ 10 (1962–2024) MD 10 (1984–2021) CT 8 (1992–2011) CO 7 (1982–2020) LA 7 (1997–2025) NH 6 (1986–2025) IL 5 (1989–2007) FL 4 (2004–2018) VA 4 (1990–2005) VT 4 (1998–2025) IN 3 (1990–1997) SC 3 (2010–2016) NC 3 (2000–2012) MS 3 (1992–2010) MA 3 (1996–2015) WI 2 (1988–2025) WV 2 (1996–2015) AK 2 (1968–1982) GA 2 (2013–2016) DC 2 (2005–2015) WY 2 (2014–2014) UT 2 (2001–2020) AZ 2 (1992–2023) KY 2 (2006–2020) MI 2 (1999–2025) DE 2 (2019–2026)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check