Schlagenhauf v. Holder

Background

A bus crash suit named Greyhound, the bus driver Robert Schlagenhauf, the tractor owner, and the trailer owner. Two co-defendants asked the trial judge to order Schlagenhauf to submit to medical and psychiatric exams after they alleged his vision and fitness were impaired. The District Court ordered nine specialist exams (later reduced to four). Schlagenhauf sought a writ to block the orders, and the appeals court denied relief.

Reasoning

The Supreme Court examined Rule 35, which allows courts to order medical or mental examinations of a party when that party’s condition is "in controversy" and there is "good cause." The Justices held Rule 35 applies to defendants as well as plaintiffs, but emphasized the movant must make an affirmative showing that each health condition sought is genuinely in dispute and explain why less intrusive discovery won’t work. The Court vacated the broad order and remanded for a narrower, reasoned ruling.

Real world impact

The ruling makes it easier for courts to authorize limited medical testing of defendants when specific health issues are truly contested, but it also blocks sweeping, routine exams in ordinary accident suits. Judges must tailor the time, place, scope, and examiner and require a concrete showing before intrusive exams are allowed. The decision sends the case back to the trial judge to apply these limits.

Dissents or concurrances

Several Justices warned about privacy and procedure. One concurred that exams were permissible here; others urged restraint or said mandamus review was improper, highlighting concerns about broad medical probes and the need for clearer safeguards.