The Supreme Court of Texas recently reversed a lower court’s ruling that awarded sanctions against a defendant who admitted to negligence during a trial over personal injury claims from a car accident.
The case centered on the defendant’s refusal to admit negligence during the discovery process before trial, which requires good-faith answers. During the trial, the defendant did not contest negligence, though he did deny gross negligence. The jury ruled that he was grossly negligent. The plaintiff sought sanctions against him for conceding at trial what he had previously denied in the discovery process.
Both the trial court and appeals court awarded sanctions in the case. The Texas Supreme Court reversed that decision.
Ms. Perry said that while it may be standard practice to request a party to admit negligence in bodily injury cases in Texas, “the Texas Supreme Court ruled such requests for admissions are no method for trying the merits.”
“The Texas Supreme Court made it clear that when faced with such merits-preclusive requests, litigants are now free to defend their cases without the fear of sanctions later,” said Ms. Perry.
She said that requests for admissions are intended to “simplify trials by eliminating matters about which there is no real controversy, but which may be difficult or expensive to prove, such as authenticity or admissibility of documents.
“They were not intended to be a trapdoor to force a party to admit they had no cause of action or ground of defense.”
The case is Christopher Medina v. Jennifer L. Zuniga, No. 17-0498.
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