In this mandamus action, the Eastland Court of Appeals held that federal tax returns are not relevant or material to the issue of the defendant’s net worth.  While the court of appeals held that a plaintiff seeking exemplary damages need not make a prima facie showing of entitlement of exemplary damages in order to obtain discovery on net worth, it held that tax returns do not reflect net worth.  The court also held the trial court abused its discretion by ordering production of  "all documents that evidence or reflect net worth" because it was overbroad.   The court of appeals’ opinion in In re House of Yahweh can be found at this link