The Dallas Court of Appeals recently held that a trial court abused its discretion by ordering production of irrelevant net worth information.  The Court first acknowledged that "net worth is relevant and discoverable when punitive damages may be awarded."  The Court  noted the "corollary to that rule is that when punitive damages are not recoverable, information about net worth is not relevant and, as a result, not discoverable."  In this case, a patron had consumed alcohol and drove her vehicle causing an accident and injuring the plaintiffs.  The driver pleaded guilty to two counts of intoxication assault.  The plaintiffs sued the defendant for serving the driver "excessive amounts of alcohol."  The Court of Appeals, citing section 41.005(a) of the Civil Practice and Remedies Code, held that punitive damages were not recoverable against the defendant because the claims arose from the criminal conduct of another.  Because punitive damages were no recoverable, the net worth information was not relevant.  Accordingly, the Court conditionally granted the petition ordering the trial court to vacate its order compelling production of net worth information.  The Court’s opinion in In re Islamorada can be found here.