5 Texas opinions name it 1 courts 2016–2025 1 in the last five years
The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Stuhler v. Stategreen1 sentence2025See Stuhler v. State, 218 S.W.3d 706 , 716–20 (Tex. Crim. | 1 | 1 |
Dale Fulmer v. Stategreen1 sentence2018See Navarro v. State, ___ S.W.3d ___, No. 10-16-00173-CR, 2017 WL 5182439 , at *1–2 (Tex. App.—Waco Nov. 8, 2017, no pet. h.) (rejecting appellant’s argument that section 21.02 violates the constitutional unanimity requirement because “the individual acts of sexual abuse are the manner and means by which the element of ‘two or more acts of sexual abuse’ is committed, and not elements in and of themselves”); Fulmer v. State, 401 S.W.3d 305, 313 (Tex. App.—San Antonio 2013, pet. ref’d) (same); McMillian v. State, 388 S.W.3d 866 , 871–73 (Tex. App.—Houston [14th Dist.] 2012, no pet.) (“We believe | 1 | 1 |
Kennedy v. Stategreen1 sentence2018See Navarro v. State, ___ S.W.3d ___, No. 10-16-00173-CR, 2017 WL 5182439 , at *1–2 (Tex. App.—Waco Nov. 8, 2017, no pet. h.) (rejecting appellant’s argument that section 21.02 violates the constitutional unanimity requirement because “the individual acts of sexual abuse are the manner and means by which the element of ‘two or more acts of sexual abuse’ is committed, and not elements in and of themselves”); Fulmer v. State, 401 S.W.3d 305, 313 (Tex. App.—San Antonio 2013, pet. ref’d) (same); McMillian v. State, 388 S.W.3d 866 , 871–73 (Tex. App.—Houston [14th Dist.] 2012, no pet.) (“We believe | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Cosio v. State
green
2 sentences2016Id. at 776 ; see Tex. R. 2016Id. at 776 ; see TEX.R.APP.P. 33.1(a). | 3 | 2016–2016 |
Holford v. State
green
1 sentence2025We hold that the trial court’s instructions require the jurors to agree that Holford committed that single act (either directly or via transferred intent), and thus the trial court did not err in failing to instruct the jury that it must agree unanimously on the manner of [decedent’s] murder. 177 S.W.3d at 463 ; see also Sanchez v. State, No. 03-13-00050-CR, 2013 WL 4487562 , at *6 (Tex. App.—Austin Aug. 15, 2013, pet. ref’d) (mem. op., not designated for publication) (“[The Court of Criminal Appeals] makes it clear that multiple theories of party liability under section 7.02 may be listed dis | 1 | 2025–2025 |
Casey v. State
green
1 sentence2018See Navarro v. State, ___ S.W.3d ___, No. 10-16-00173-CR, 2017 WL 5182439 , at *1–2 (Tex. App.—Waco Nov. 8, 2017, no pet. h.) (rejecting appellant’s argument that section 21.02 violates the constitutional unanimity requirement because “the individual acts of sexual abuse are the manner and means by which the element of ‘two or more acts of sexual abuse’ is committed, and not elements in and of themselves”); Fulmer v. State, 401 S.W.3d 305, 313 (Tex. App.—San Antonio 2013, pet. ref’d) (same); McMillian v. State, 388 S.W.3d 866 , 871–73 (Tex. App.—Houston [14th Dist.] 2012, no pet.) (“We believe | 1 | 2018–2018 |
Ngo v. State
green
1 sentence2018He notes that, regardless of legislative intent, it is a violation of his due process rights for the State to allege a “laundry list of different criminal acts and let the jurors take their pick on which each believes the defendant committed.” Ngo, 175 S.W.3d at 745 . | 1 | 2018–2018 |
Bruce Alan McMillian v. State
green
1 sentence2018See Navarro v. State, ___ S.W.3d ___, No. 10-16-00173-CR, 2017 WL 5182439 , at *1–2 (Tex. App.—Waco Nov. 8, 2017, no pet. h.) (rejecting appellant’s argument that section 21.02 violates the constitutional unanimity requirement because “the individual acts of sexual abuse are the manner and means by which the element of ‘two or more acts of sexual abuse’ is committed, and not elements in and of themselves”); Fulmer v. State, 401 S.W.3d 305, 313 (Tex. App.—San Antonio 2013, pet. ref’d) (same); McMillian v. State, 388 S.W.3d 866 , 871–73 (Tex. App.—Houston [14th Dist.] 2012, no pet.) (“We believe | 1 | 2018–2018 |
Render v. State
green
1 sentence2018See Navarro v. State, ___ S.W.3d ___, No. 10-16-00173-CR, 2017 WL 5182439 , at *1–2 (Tex. App.—Waco Nov. 8, 2017, no pet. h.) (rejecting appellant’s argument that section 21.02 violates the constitutional unanimity requirement because “the individual acts of sexual abuse are the manner and means by which the element of ‘two or more acts of sexual abuse’ is committed, and not elements in and of themselves”); Fulmer v. State, 401 S.W.3d 305, 313 (Tex. App.—San Antonio 2013, pet. ref’d) (same); McMillian v. State, 388 S.W.3d 866 , 871–73 (Tex. App.—Houston [14th Dist.] 2012, no pet.) (“We believe | 1 | 2018–2018 |
Jacobsen v. State
green
1 sentence2018See Navarro v. State, ___ S.W.3d ___, No. 10-16-00173-CR, 2017 WL 5182439 , at *1–2 (Tex. App.—Waco Nov. 8, 2017, no pet. h.) (rejecting appellant’s argument that section 21.02 violates the constitutional unanimity requirement because “the individual acts of sexual abuse are the manner and means by which the element of ‘two or more acts of sexual abuse’ is committed, and not elements in and of themselves”); Fulmer v. State, 401 S.W.3d 305, 313 (Tex. App.—San Antonio 2013, pet. ref’d) (same); McMillian v. State, 388 S.W.3d 866 , 871–73 (Tex. App.—Houston [14th Dist.] 2012, no pet.) (“We believe | 1 | 2018–2018 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.