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Tex. R. Civ. P. 198.2, 198.3 · deemed admitted, and withdrawal

They were deemed admitted the day the deadline passed. Quietly.

Requests for admission are the only discovery in Texas that decides the case by being ignored. No motion, no order, no hearing — miss the deadline and every request is admitted as a matter of law. Cases have been lost to a stack of paper nobody opened.

The rule that makes them deadly also makes them undoable. Rule 198.3 lets the court withdraw them on good cause where the other side is not unduly prejudiced, and the Supreme Court of Texas has been notably willing to say so.

or answer one question
Rule 198 · what is admitted, and can it be withdrawn

What has happened since the responses were due?

Deemed admissions are undone far more readily before they have been used than after.

What date were the responses due?

Where these answers come from

We hold the published Texas case law in our own index and query it directly. No vendor sits between the question and the answer. That is the reason a discrete motion can carry a price on a web page instead of an hourly rate and a hope.

881,255
Texas decisions indexed
6 ms
Median query, this posture
841,641
Parallel citations mapped
26 Jun 2026
Index current through

Authority that may bear on your posture Attorney reviewed

Pulled from our index for this mechanism and read by a lawyer before it went on this page. A green check means the decision is on point for this posture. It is not a statement that the case has been shepardized, and it is not a representation about its current precedential standing.

Wheeler v. Green
157 S.W.3d 439 (Tex. 2005)
The case that matters most here. Deemed admissions used to decide the merits implicate due process, and the same standard that excuses a default — accident or mistake rather than conscious indifference — is good cause to withdraw them. Decided for a pro se litigant who missed the deadline by two days.
cited by
497
Marino v. King
355 S.W.3d 629 (Tex. 2011)
Reaffirms Wheeler and goes further: merits-preclusive deemed admissions should be withdrawn absent flagrant bad faith or callous disregard. A missed deadline, without more, is not that.
cited by
97
Carpenter v. Cimarron Hydrocarbons Corp.
98 S.W.3d 682 (Tex. 2002)
The good-cause framework for late discovery responses generally, and the source of the standard Wheeler applies.
cited by
468
Texas Integrated Conveyor Systems v. Innovative Conveyor Concepts
300 S.W.3d 348 (Tex. App.—Dallas 2009, pet. denied)
Where withdrawal was refused, and why. Useful for seeing what actually distinguishes a recoverable posture from one that is not.
cited by
200

Counts are the number of later decisions in our index that cite the case. A high count means a case has been used, not that it is good law. Nothing on this page is a citator signal and we will not show one until it is produced by reading opinions rather than counting them.

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