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Keywords

contractdefendantdamagesnegligenceappealhearingpleacorporationcivil procedure
defendantdamagesnegligenceappealcitizenshipcivil procedure

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Schlagenhauf v. Holder, 379 U.S. 104, 85 S.Ct. 234, 13 L.Ed.2d 152, 9 Fed.R.Serv.2d 35a.1, 1

Facts

The case arose from a negligence action involving a bus collision with a tractor-trailer, where the passengers sought damages for personal injuries. The defendants included The Greyhound Corporation, the bus driver Robert L. Schlagenhauf, and others. Following the accident, Contract Carriers and National Lead petitioned the District Court for Schlagenhauf to undergo mental and physical examinations, claiming his mental and physical condition was 'in controversy' due to allegations made in their pleadings. The District Court ordered Schlagenhauf to submit to nine examinations without a hearing, leading to the mandamus petition.

An action based on diversity of citizenship was brought in the District Court seeking damages arising from personal injuries suffered by passengers of a bus which collided with the rear of a tractor-trailer.

Issue

Whether the District Court had the authority to order mental and physical examinations of a defendant under Rule 35(a) of the Federal Rules of Civil Procedure when the defendant's mental or physical condition was not 'in controversy' and 'good cause' was not shown.

This case involves the validity and construction of Rule 35(a) of the Federal Rules of Civil Procedure as applied to the examination of a defendant in a negligence action.

Rule

Rule 35(a) of the Federal Rules of Civil Procedure allows a court to order a party to submit to a physical or mental examination only if that party's mental or physical condition is 'in controversy' and 'good cause' is shown for the examination.

Rule 35(a) provides: ‘Physical and Mental Examination of Persons. (a) Order for Examination. In an action in which the mental or physical condition of a party is in controversy, the court in which the action is pending may order him to submit to a physical or mental examination by a physician.

Analysis

The Supreme Court analyzed whether the requirements of Rule 35 were met in this case. It determined that the allegations made by the other parties regarding Schlagenhauf's mental and physical condition were insufficient to establish that his condition was 'in controversy' or that 'good cause' existed for the examinations. The Court emphasized that the movants must provide an affirmative showing that the conditions for examination were genuinely in controversy and that good cause existed for each requested examination.

The petitioner, however, also alleged that, even if Rule 35 gives a district court power to order mental and physical examinations of a defendant in an appropriate case, the District Court here exceeded that power in ordering examinations when petitioner's mental and physical condition was not ‘in controversy’ and no ‘good cause’ was shown, both as expressly required by Rule 35.

Conclusion

The Supreme Court vacated the judgment of the Court of Appeals and remanded the case to the District Court to reconsider the examination order in light of the guidelines established in the opinion.

Accordingly, the judgment of the Court of Appeals is vacated and the case remanded to the District Court to reconsider the examination order in light of the guidelines herein formulated and for further proceedings in conformity with this opinion.

Who won?

Robert L. Schlagenhauf prevailed in the case as the Supreme Court found that the District Court's order for examinations was not justified under Rule 35.

Mr. Justice Goldberg, held that the record failed to show that mental or physical condition of driver of bus colliding with rear end of tractor-trailer was in controversy or that there was good cause for his physical or mental examination.

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