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5 Texas opinions name it 2 courts 1991–2026 2 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 |
|---|---|---|
Toussie v. United Statesred2 sentences2026App. 1998) (quoting from Toussie v. United States, 397 U.S. 112, 115 (1970)) (“Generally, when each of the elements of a crime have occurred, the crime is complete. . . . ‘[T]he doctrine of continuing offenses should be applied in only limited circumstances. . . . [S]uch a result should not be reached unless the explicit language of the substantive criminal statute compels such a conclusion or the nature of the crime is such that Congress must assuredly have intended that it be treated as continuing.’”) (first ellipsis inserted, second ellipsis in Barnes, brackets inserted); cf. Howlett v. Sta 2024See Toussie v. United States, 397 U.S. 112, 115 (1970) (discussing doctrine of continuing offenses); Barnes v. State, 824 S.W.2d 560, 562 (Tex. Crim. | 3 | 5 |
Barnes v. Stategreen2 sentences2024See Toussie v. United States, 397 U.S. 112, 115 (1970) (discussing doctrine of continuing offenses); Barnes v. State, 824 S.W.2d 560, 562 (Tex. Crim. 2006Barnes, 824 S.W.2d at 562 . | 1 | 2 |
Howlett v. Stategreen1 sentence2026App. 1998) (quoting from Toussie v. United States, 397 U.S. 112, 115 (1970)) (“Generally, when each of the elements of a crime have occurred, the crime is complete. . . . ‘[T]he doctrine of continuing offenses should be applied in only limited circumstances. . . . [S]uch a result should not be reached unless the explicit language of the substantive criminal statute compels such a conclusion or the nature of the crime is such that Congress must assuredly have intended that it be treated as continuing.’”) (first ellipsis inserted, second ellipsis in Barnes, brackets inserted); cf. Howlett v. Sta | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Spakes v. State
green
1 sentence2026App. 1999) (“[W]e cannot say the Court of Appeal’s holding that ‘the offense continued to occur as long as the unauthorized valve was in place and the owner suffered pecuniary loss’ [from the continued diversion of gas] was clearly erroneous.”) (brackets inserted and bracketed material added for clarity); Spakes v. State, 913 S.W.2d 597 , 598 n.* (Tex. Crim. | 1 | 2026–2026 |
Proctor v. State
green
1 sentence2024App. 1991) (same), overruled on other grounds by Proctor 13 v. State, 967 S.W.2d 840 (Tex. Crim. | 1 | 2024–2024 |
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.