Medina v. Zuniga (Opinion)Annotate this Case
The Supreme Court reversed the decision of the court of appeals affirming the trial court's decision awarding sanctions in favor of Plaintiff in this negligence case, holding that a trial court may not sanction a party who fails to admit negligence during discovery but concedes it at trial.
At the beginning of litigation, Plaintiff served Defendant with requests for admissions asking Defendant to concede with negligence and confess he was the sole cause of the accident at issue in this case. Defendant denied those requests. At trial, Defendant conceded ordinary negligence but contested Plaintiff's gross negligence claim. After trial, Plaintiff moved for an award of reasonable expenses and attorney's fees incurred in proving the negligence issues that Defendant ultimately conceded. The trial court awarded sanctions. The court of appeals affirmed. The Supreme Court reversed, holding (1) the trial court abused its discretion in awarding sanctions; and (2) no evidence supported the jury's finding that Defendant was grossly negligent.