Tracker record · Texas · Judgment

Office of the Attorney General v. PFLAG, Inc.

Industry: All industries · Track: Litigation and Enforcement

The Supreme Court of Texas held March 13, 2026 (No. 24-0892) that a DTPA civil investigative demand is closely analogous to civil discovery: the Attorney General needs only a reasonable belief that the recipient may have relevant material, and courts may not substitute their own view of whether the investigation will prove fruitful. The Court reversed the trial court's order protecting PFLAG and remanded to Travis County district court for further proceedings, directing production of specified categories (contingency plans or alternative care options, provider referrals and lists, communications with identified health care providers, and records tied to the executive director's affidavit comments) while holding other requests were not clearly relevant and need not be produced. The opinion retains judicial limits: a CID remains subject to the usual discovery objections, including privilege and burden, and constitutional limits; a trial court would have good cause to set aside a CID where the office proffers no reasonable explanation. The office also agreed to allow redactions to preserve the anonymity of families or children named in the documents.

Status

Legal status
Decided March 13, 2026; reversed and remanded (Decided March 13, 2026, Supreme Court of Texas, No. 24-0892; DTPA CID subject to 'reasonable belief' standard; protective order reversed; remanded to Travis County district court; privilege and discovery objections preserved)
Allegation or finding
Finding or order
Applicability
Construes DTPA ยง17.61
Enforceability
Binding Texas Supreme Court precedent
Procedural posture
Reversed and remanded March 13, 2026; production ordered as tailored by the Court; case returned to Travis County district court for further proceedings
Law checked through
October 12, 2026
Primary source
Opinion, txcourts.gov; Texas AG release, March 16, 2026
Citation
Office of the Attorney General v. PFLAG, Inc., No. 24-0892 (Tex. Mar. 13, 2026)
Court
Supreme Court of Texas
Docket
No. 24-0892
Source
Opinion, txcourts.gov; Texas AG release, March 16, 2026

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