In Medina v. Zuniga, No.: 17-0498, the
Texas Supreme Court reversed and rendered judgment that the trial court abused
its discretion in awarding sanctions. The case stemmed from a car accident in a
high school parking lot (seemingly, from a practical joke). Medina drove his
truck through the parking lot accelerating to high speeds and eventually
striking Zuniga who sued Medina for negligence and gross negligence.
During
discovery, Zuniga served Medina with various Requests for Admission (“RFA”)
asking Medina to admit that he was driving negligently, among other items.
Medina predictably denied the allegations. At trial, however, Medina conceded
that he was indeed driving negligently—but not with gross negligence. Zuniga
requested that the trial court impose sanctions on Medina for failing to admit
this fact during discovery, pursuant to Rule 215.4 of the Texas Rules of Civil
Procedure, which allows for reasonable expenses and attorney’s fees incurred in
proving an RFA that was denied and later admitted or proven at trial. Both the
trial court and the Fourth Court of Appeals agreed with Zuniga and ordered
Medina to pay Zuniga’s attorney’s fees related to proving the later admitted
negligence claim.
The Texas Supreme Court disagreed, re-affirming that RFAs were not intended to be used as a demand that a defendant admit that no grounds of defense exists. The Court compared denying RFAs and later admitting those requests to a general denial at the outset of a case. In other words, a defendant is entitled to deny the claims against her, so long as “good reason” exists for failing to admit. At the discovery stage, the Court noted, parties are entitled to develop their cases without the “fear” for being punished later for defending themselves at the case’s outset.
