In personal-injury cases trial courts do not grant motions for a party to undergo a mental or physical examination as a matter of right. Instead, Texas Rule of Civil Procedure 204 gives a trial court the discretion to order an exam only if the movant shows good cause and demonstrates that the other party’s mental or physical condition is in controversy.
“Good cause” and “in controversy” are separate but related concepts. In Coates v. Whittington (1988), the Texas Supreme Court held that a party could establish good cause under the predecessor version of Rule 204 by showing three things: The exam is relevant to the issues generally in controversy in the case, there is a reasonable nexus between the condition in controversy and the exam sought, and it is not possible to obtain the desired information through means less intrusive than a compelled exam.
