No good cause, no special master.

The trial court in In re Alford appointed a special master to resolve discovery issues. Tex. R. Civ. P. 171 gives a trial court the power to “in exceptional cases, for good cause appoint a master in chancery.” Case law clarifies that “a special master may not be appointed merely because ‘a case is complicated or time-consuming, or [because] the court is busy.'” Here, the Fifth Court granted mandamus relief, noting “no indication that the case is unusually complicated or requires specialized knowledge,” and citing this exchange from the hearing on relators’ objection to the master’s appointment:

[Counsel]: Can you explain on the record what the good cause is and what the reasons for the appointment of this order is?

THE COURT: No, but thank you for asking.

No. 05-22-00240-CV (May 16, 2022).