in Re Michael G. Brown

CourtCourt of Appeals of Texas
DecidedJanuary 16, 2009
Docket14-08-00548-CV
StatusPublished

This text of in Re Michael G. Brown (in Re Michael G. Brown) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
in Re Michael G. Brown, (Tex. Ct. App. 2009).

Opinion

Petition for Writ of Mandamus Denied and Plurality and Dissenting Opinions filed January 16, 2009

Petition for Writ of Mandamus Denied and Plurality and Dissenting Opinions filed January 16, 2009.                                                                                                                       

In The

Fourteenth Court of Appeals

____________

NO. 14-08-00548-CV

IN RE MICHAEL G. BROWN, Relator

ORIGINAL PROCEEDING

WRIT OF MANDAMUS

D I S S E N T I N G   O P I N I O N

Because the plurality determines that the trial court=s failure to comply with the rules of civil procedure governing a trial court=s order for a psychiatric evaluation does not constitute an abuse of discretion, I respectfully dissent. 

I agree that, notwithstanding Michael=s non-suit of his claims for affirmative relief, his mental condition may remain at issue because the trial court ultimately must craft a possession-and-access order that is in the children=s best interests.  But although a party=s mental condition often is at issue when a trial court must decide conservatorship matters, a psychiatric evaluation is not always necessary or justified.  


Texas Rule of Civil Procedure 204.1 prescribes certain requirements and procedural safeguards which must be met for a trial court to compel a litigant to submit to the extremely invasive measure of an involuntary psychiatric evaluation.  Here, the mandamus record before us is not only devoid of evidence that the trial court complied with Rule 204.1=s requirements, but establishes instead that the trial court disregarded them.  Inasmuch as the trial court has no discretion to incorrectly determine or apply the law, I would conclude that the order as written presents a clear abuse of discretion for which there is no adequate remedy on appeal.[1]  I therefore would grant mandamus relief.


Under our rules of civil procedure, a psychiatric evaluation may not be compelled absent good cause.  Tex. R. Civ. P. 204.1(c).  AGood cause@ is established if (a) the examination will produce or lead to relevant evidence, (b) there is a reasonable nexus between the conditions in controversy and the examination sought, and (c) it is not possible to obtain the information desired through less invasive means.  Coates v. Whittington, 758 S.W.2d 749, 752 (Tex. 1988).  Here, the trial court failed to adequately consider these factors before compelling Michael to undergo a psychiatric evaluation.  To the contrary, the trial court expressly stated that, without hearing any evidence,[2] it would appoint an amicus attorney, require Michael to undergo instanter drug testing, and order him to submit to a psychiatric evaluation.[3]  Michael then non-suited all of his requests for affirmative relief and stipulated to Darlina=s request for restricted access, and although the trial court was still required to determine whether such restrictions were in the children=s best interest,[4] the court=s need for information must be met through the least intrusive means. 


Due consideration of less intrusive means also may affect the scope of the evaluation. APsychiatric evaluations vary according to their purpose.@  Michael J. Vergare et al., Practice Guideline for the Psychiatric Evaluation of Adults, in Practice Guidelines for the Treatment of Psychiatric Disorders, at 1, 6 (Am. Psychiatric Ass=n, Compendium 2006).  Here, however, no purpose, scope, or conditions were specified in the order at issue.  Cf. Tex. R. Civ. P. 204.1(d) (requiring an order for a mental examination to Aspecify the time, place, manner, conditions, and scope of the examination and the person or persons by whom it is to be made@); Coates, 758 S.W.2d at 752.  Because it contains no limitations on the scope, the examiner may probe any aspect of Michael=s thoughts, behavior, abilities, beliefs, health, or history that could fall under the rubric of a psychiatric evaluation.  See generally Dana Baerger et al, Methodology for Reviewing the Reliability and Relevance of Child Custody Evaluations, 18 J. Am. Acad. Matrim. Law. 35, 50B52 (2002) (recognizing the pitfalls inherent in a general order for a psychiatric evaluation, such as the likelihood that Aevaluators will address irrelevant issues that confuse the litigation and increase the cost of the evaluation@).[5]  The result is that the examiner is permitted to conduct a maximally-intrusive evaluation despite the absence of any record evidence that less-intrusive means are unavailable.


I agree that psychiatric or psychological evaluations have a place in conservatorship determinations.  Indeed, a psychiatric evaluation might be a very useful tool in this case.  But, it is only one of the tools available to a trial court in crafting a conservatorship order and should not be ordered without consideration of the factors and evidence justifying its use.  Given the inherently invasive nature of a psychiatric evaluation, it is not within the trial court=

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Bluebook (online)
in Re Michael G. Brown, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-michael-g-brown-texapp-2009.