In re State Farm Lloyds
- Court
- Texas Supreme Court (State high court)
- Decided
- 2017
- Citation
- 520 S.W.3d 595 (Tex. 2017)
- Standard applied
- Tex. R. Civ. P. 192.4, 196.4 — form of production and proportionality
What the court held
A requesting party is not automatically entitled to production of electronically stored information in native, metadata-bearing form. Metadata may be discoverable when relevant, but relevance must be obvious or concretely linked to a claim or defence; hypothetical needs, surmise and suspicion carry no weight. The form of production is governed by proportionality, and the court remanded for that analysis.
Why
The court distinguished native formats, which carry metadata, from static formats such as TIFF and PDF, which strip it and are searchable only through optical character recognition. It accepted that metadata is sometimes important or even dispositive, and framed the test as whether the who, what, where, when and why of the data's creation is an actual issue in the case rather than a theoretical one. Discoverability, it emphasised, does not settle the manner of production.
Our reading — not the court’s words
Why this matters in practice
This is the leading state-court statement of the rule practitioners keep relitigating: asking for native files is not self-justifying, and the request has to be tied to a specific evidentiary need. That means the argument for native production is a forensic argument — name the metadata field, say what it would show, and connect it to an element. The court's taxonomy of substantive, system and embedded metadata is also a useful vocabulary for drafting an ESI protocol before the dispute arises.
This paragraph is Legal Cyber Academy’s editorial assessment of the decision’s practical importance. The court said none of it. For what the court actually said, read the opinion.
Additional detail
Tags: metadata · native format · form of production · proportionality
Cited 98times in CourtListener’s corpus at the time this entry was compiled. Treat it as a rough measure of influence, not of correctness.
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Summarised from the opinion as retrieved from CourtListener. Reference material, not legal advice. Back to the repository.