In Re Schindler Elevator Corporation v. the State of Texas

CourtTexas Court of Appeals, 4th District (San Antonio)
DecidedJanuary 14, 2026
Docket04-25-00583-CV
StatusPublished

This text of In Re Schindler Elevator Corporation v. the State of Texas (In Re Schindler Elevator Corporation v. the State of Texas) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 4th District (San Antonio) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re Schindler Elevator Corporation v. the State of Texas, (Tex. Ct. App. 2026).

Opinion

Fourth Court of Appeals San Antonio, Texas

MEMORANDUM OPINION No. 04-25-00583-CV

IN RE SCHINDLER ELEVATOR CORPORATION

Original Mandamus Proceeding 1

Opinion by: Lori I. Valenzuela, Justice

Sitting: Irene Rios, Justice Lori I. Valenzuela, Justice Lori Massey Brissette, Justice

Delivered and Filed: January 14, 2026

PETITION FOR WRIT OF MANDAMUS CONDITIONALLY GRANTED

In this original proceeding arising from a personal injury lawsuit, relator Schindler Elevator

Corporation asserts the trial court abused its discretion by denying its motion to compel an

independent medical examination (“IME”) of real party in interest Jennifer Keith. Because

Schindler satisfied the requirements necessary to compel an IME under Texas Rule of Civil

Procedure 204.1, we conditionally grant mandamus relief.

1 This proceeding arises out of Cause No. 2023CI22952, styled Jennifer Keith v. Valcor Properties, LLC a/k/a Valcor Commercial Real Estate; Services Life & Casualty Insurance Co., Service Group Holdings, Inc., and Schindler Elevator Corporation, pending in the 45th Judicial District Court, Bexar County, Texas, the Honorable Christine Vasquez Hortick presiding. 04-25-00583-CV

BACKGROUND

In the underlying dispute, Keith alleges, among other things, that she suffered a traumatic

brain injury when an elevator malfunctioned. Schindler was the service repair company that

maintained the elevator in question. Keith sued Schindler and other defendants and sought

damages for her past and future pain and suffering, mental anguish, lost wages, lost earning

capacity, physical impairment, disfigurement, and medical expenses. In support of her claims and

alleged damages, Keith retained a neuropsychologist to examine her and prepare a report, which

Keith produced to Schindler. Schindler moved to compel Keith to submit to an IME, contending

that it had shown good cause for the exam and that Keith’s claims and alleged damages placed her

mental condition in controversy. The trial court denied the motion to compel, and Schindler filed

a petition for writ of mandamus. 2

DISCUSSION

Standard of Review

“Mandamus is an extraordinary remedy granted only when the relator shows that the trial

court abused its discretion and that no adequate appellate remedy exists.” In re H.E.B. Grocery

Co., L.P., 492 S.W.3d 300, 302 (Tex. 2016) (orig. proceeding) (per curiam). “When a trial court

fails to analyze or apply the law correctly, it has clearly abused its discretion.” In re Sherwin-

Williams Co., 668 S.W.3d 368, 370 (Tex. 2023) (orig. proceeding) (per curiam) (internal quotation

marks omitted).

Applicable Law

Because the forced examination of an individual involves the intrusion into one’s personal

liberties beyond that posed by other kinds of discovery, heightened scrutiny must be satisfied

2 We requested responses from Keith and respondent. No responses were filed.

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before an individual can be compelled to submit to an IME. See In re CSX Corp., 124 S.W.3d 149,

152 (Tex. 2003) (“Our procedural rules define the general scope of discovery as any unprivileged

information that is relevant to the subject of the action, even if it would be inadmissible at trial, as

long as the information sought is ‘reasonably calculated to lead to the discovery of admissible

evidence.’”) (quoting TEX. R. CIV. P. 192.3(a)); cf. TEX. R. CIV. P. 204.1(c), (d); In re Sherwin-

Williams Co., 668 S.W.3d at 370–71 (“The rule’s ‘good cause requirement . . . balance[s] the

movant’s right to a fair trial and the other party’s right to privacy.’”) (alterations in original,

quoting In re H.E.B. Grocery Co., 492 S.W.3d at 303).

Relevant here, an examination may be compelled “only for good cause shown” and when

either the “mental or physical condition . . . of a party . . . is in controversy” or “except as provided

in Rule 204.43 . . . when the party responding to the motion has designated a psychologist as a

testifying expert or has disclosed a psychologist’s records for possible use at trial.” TEX. R. CIV.

P. 204.1(c); see also In re H.E.B. Grocery Co., 492 S.W.3d at 303 (providing Rule 204.1(c)(1)’s

requirements “cannot be satisfied by mere conclusory allegations of the pleadings–nor by mere

relevance to the case”) (internal quotation marks omitted). “To establish good cause, the movant

must show that (1) the examination is relevant to the issue in controversy and is likely to lead to

relevant evidence, (2) there is a reasonable nexus between the examination and the condition in

controversy, and (3) the desired information cannot be obtained by less intrusive means.” In re

Sherwin-Williams Co., 668 S.W.3d at 371 (internal quotation marks omitted).

Analysis

Here, it is undisputed that Keith’s mental condition is in controversy. Keith is seeking

damages for, among other things, a traumatic brain injury she alleges she suffered as a result of

3 Rule 204.4 applies to cases arising under the Family Code and therefore is not relevant here. TEX. R. CIV. P. 204.4.

-3- 04-25-00583-CV

Schindler’s failure to properly maintain an elevator in a safe working condition. Therefore, to be

entitled to an IME, Schindler must have established good cause for the exam. See id.

First, as to relevance, the issues in controversy are the existence and extent of Keith’s

injuries, and specifically here, the existence and severity of her traumatic brain injury. Schindler’s

request for an IME on the same issues in controversy satisfies the relevancy requirement of the

good cause analysis. See In re H.E.B. Grocery Co., 492 S.W.3d at 303; TEX. R. CIV. P. 204.1(c)(1).

Additionally, Schindler argued both below and in this court—and Keith did not dispute—that

Keith’s retained neuropsychologist will be testifying at trial. See TEX. R. CIV. P. 204.1(c)(2).

Second, Schindler has also satisfied the reasonable nexus requirement. “Again, the purpose

of the examination is to determine the existence, nature, and extent of the injuries” Keith sustained

that are attributable to Schindler. In re H.E.B. Grocery Co., 492 S.W.3d at 303. The controversy

revolves around Keith’s mental condition and the extent of her alleged damages related to the

elevator Schindler maintained. Id. (“The condition in controversy is [plaintiff’s] physical health—

his past, present, and future injuries related to the fall and other causes, and the extent of his

damages.”). Therefore, “[t]he requested examination . . . directly relates to the condition in

controversy and satisfies the nexus requirement.” Id.

Third, Schindler satisfied the final requirement of good cause. As noted above, in support

of her traumatic brain injury allegations attributable to Schindler’s negligence, Keith has retained

a neuropsychologist expert who has prepared a report. Schindler’s motion to compel included an

unsworn declaration from a retained expert of its own, Dr. Katrina Belen, that explained the general

kinds of testing Dr. Belen intended to conduct, the nexus between that testing and Keith’s claimed

injuries, and why Dr. Belen believed her examination would yield useful information. In addition

to noting that the results of the testing Keith had already undergone may be outdated, Dr. Belen

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Related

In Re CSX Corp.
124 S.W.3d 149 (Texas Supreme Court, 2003)
Walker v. Packer
827 S.W.2d 833 (Texas Supreme Court, 1992)
In re H.E.B. Grocery Co.
492 S.W.3d 300 (Texas Supreme Court, 2016)

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In Re Schindler Elevator Corporation v. the State of Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-schindler-elevator-corporation-v-the-state-of-texas-txctapp4-2026.