Background
Salesforce, Inc. sought mandamus relief from a February 13, 2026 trial-court order that partially granted a motion by the Jane Doe real parties in interest to compel the production of documents. The discovery dispute arose in multidistrict litigation pending as In re Jane Doe Cases, Master Docket Case No. 2020-28545, in the 11th District Court of Harris County.
Salesforce argued that the trial court abused its discretion by ordering it to produce two documents protected by the attorney-client privilege. The challenged order was issued by Judge Mark Davidson.
The Court’s Holding
The First Court of Appeals concluded that Salesforce failed to establish an entitlement to mandamus relief. It therefore denied the petition for a writ of mandamus.
The memorandum opinion did not provide further analysis of the privilege claim or explain why Salesforce failed to satisfy the requirements for mandamus relief. The court also dismissed all pending motions as moot.
Key Takeaways
- Salesforce did not obtain mandamus relief from the order compelling production of two documents it claimed were attorney-client privileged.
- The court’s brief memorandum opinion states only that Salesforce failed to establish its entitlement to mandamus relief.
- All pending motions in the appellate proceeding were dismissed as moot.
Why It Matters
The decision leaves Salesforce without the extraordinary appellate relief it requested from the discovery order in the underlying multidistrict litigation. Because the court offered no substantive privilege analysis, the opinion provides little guidance on the boundaries of attorney-client privilege or the circumstances in which a similar discovery order would warrant mandamus relief.