In Decker v. Lindsay, 824 S.W.2d 247 / 1992 Tex. App. LEXIS 210, the plaintiff is suing over the question of whether a party be compelled to participate in an ADR procedure despite its objections. Plaintiffs argue that the judge's act of requiring them to go to ADR when they clearly have indicated that they do not want to is violative of their rights. The court found for the plaintiffs as it violates the open courts provision that states that negotiation cannot be ordered.
Decker v. Lindsay
Texas First Court of Appeals. Dec. 3, 1991http://www.1stcoa.courts.state.tx.us/opinions/case.asp?FilingID=67735