City of Mobile v. Regenia T. Howard.

Summary

The court held that the trial court abused its discretion by ordering the City to produce law-enforcement investigative materials under Rule 27 without a substantial-evidence showing of undue hardship and unavailability from other reasonable sources. The requested materials were subject to statutory protection, and the confidentiality condition imposed by the trial court did not eliminate the required showing. The order was reversed and the case remanded.