Texas Supreme Court Reverses Award of Attorneys’ Fees Sanctions Under Rule 215.4 Where the Defendant Does Not Make Appropriate Admissions.

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.

By: Eric Shalolashvili

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