State ex rel. Mass. Mut. Life Ins. Co. v. Jefferson County Circuit Court (Sanders)

This case was before the Supreme Court on a writ of prohibition brought by Massachusetts Mutual Life Insurance Company (MassMutual) seeking to prohibit the circuit court from enforcing two orders requiring the president and CEO of MassMutual to submit to depositions. MassMutual argued (1) the orders requiring its president to submit to depositions were properly the subject of a writ of prohibition, and (2) the orders compelling the depositions of this high-ranking corporate executive, despite his lack of any personal or unique knowledge about the cases, were clearly erroneous and constituted an abuse of the circuit court's discretion. The Supreme Court issued the writ after adopting the apex deposition rule, a framework for assessing whether the deposition of a high-ranking corporate official is proper, holding that because the circuit court, in this case, did not make findings of fact or conclusions of law, there was an insufficient basis to sustain the circuit court's orders.