Stelly v. Papania

In Stelly v. Papania, 927 S.W.2d 620, 621, 39 Tex. Sup. Ct. J. 878 (Tex. 1996), for example, the defendant filed a motion for summary judgment claiming that he did not own the property on which the plaintiff slipped and fell. Preliminarily, the defendant sought leave to withdraw and amend his prior answer to requests for admissions in which he had admitted owning the premises. Id. at 621. The Court noted that, in the analogous deemed-admissions context, a party demonstrates good cause to withdraw admissions by showing that its failure to answer was not intentional or the result of conscious indifference, but was accidental or the result of mistake, and that the parties relying on the responses will not be unduly prejudiced. Id. at 622. Applying that standard to the defendant's motion to withdraw and amend prior admissions, we emphasized that the civil procedure rules' purpose is to fairly and equitably adjudicate parties' claims, and not to prevent a litigant from presenting his case. Id. Because the defendant presented evidence of good cause, we held that the trial court did not abuse its discretion in allowing the defendant to withdraw and amend his answers before the trial court considered the defendant's summary-judgment motion. Id.