Coates v. Whittington

In Coates v. Whittington, 758 S.W.2d 749, 751 (Tex. 1988) the Texas Supreme Court set forth a test for when the trial court may compel a party to undergo a mental examination. The court stated that the rule "places an affirmative burden on the movant to meet a two-pronged test: (1) the movant must show that the party's mental condition is 'in controversy'; and (2) the movant must demonstrate that there is 'good cause' for a compulsory mental examination." Id. "In the absence of an affirmative showing of both prongs of the test, a trial court may not order an examination." Id. The court also stated that "the movant must demonstrate that the information sought is required to obtain a fair trial and therefore necessitates intrusion upon the privacy of the person he seeks to have examined." Id.