statutory notice requirement (Texas) · Go Syfert
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statutory notice requirement in Texas

38 Texas opinions name it 4 courts 1953–2025 3 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.

Followed or applied (21)

CaseFollowedCited
Whitson v. Harrisgreen
texapp · 1990 · cited in 3 Texas opinions naming this issue, 1994–1994
2 sentences

1994In Whitson , this Court said that unless the receivership court orders a different manner of notice, service of notice by first-class mail satisfies the statutory notice requirement of section 3(h); proof of receipt of that notice is not required. 5 Whitson, 792 S.W.2d at 208 (emphasis added).

1994In Whitson , this Court said that unless the receivership court orders a different manner of notice, service of notice by first-class mail satisfies the statutory notice requirement of section 3(h); proof of receipt of that notice is not required. 5 Whitson, 792 S.W.2d at 208 (emphasis added).

33
Roccaforte v. Jefferson Countygreen
tex · 2011 · cited in 5 Texas opinions naming this issue, 2011–2012
2 sentences

2012A similar issue, regarding the proper consequences for noncomplianee with a statutory notice requirement, was recently addressed by the Texas Supreme Court in Roccaforte v. Jefferson County, 341 S.W.3d at 926-27 .

2012A similar issue, regarding the proper consequences for noncompliance with a statutory notice requirement, was recently addressed by the Texas Supreme Court in Roccaforte v. Jefferson County , 341 S.W.3d at 926-27 .

25
Hagedorn v. Tisdalegreen
texapp · 2002 · cited in 3 Texas opinions naming this issue, 2006–2016
2 sentences

2006As the court in Emeritus reasoned, if abatement under section 74.051 tolled the 120-day period, “ ‘a plaintiff would in fact be rewarded with additional time for the filing of his report by his failure to comply with the statutory notice requirement.”’ Id. (quoting Hagedorn v. Tisdale, 73 S.W.3d 341, 348 (Tex.App.-Amarillo 2002, no pet.)).

2006As the court in Emeritus reasoned, if abatement under section 74.051 tolled the 120-day period, A > a plaintiff would in fact be rewarded with additional time for the filing of his report by his failure to comply with the statutory notice requirement. = @ Id . (quoting Hagedorn v. Tisdale , 73 S.W.3d 341, 348 (Tex. App. C Amarillo 2002, no pet.)).

23
Spiegel v. Strothergreen
texapp · 2008 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., Roccaforte v. Jefferson County, 341 S.W.3d 919 (Tex.2011) (holding county officials’ acknowledgement of hand-delivered notice satisfied statute’s “requisite notice” even though statute required notice to be delivered by certified or registered mail); Goforth v. Bradshaw, 296 S.W.3d 849, 851 (Tex.App.-Texarkana 2009, no pet.) (holding expert reports and CVs sent by regular mail within statutory deadline, which defendants acknowledged receiving, were timely served even though statute required the documents to be served through registered or certified mail); Spiegel v. Strother, 262 S.

2011See, e.g. , Roccaforte v. Jefferson County , 341 S.W.3d 919 (Tex. 2011) (holding county officials’ acknowledgement of hand-delivered notice satisfied statute’s “requisite notice” even though statute required notice to be delivered by certified or registered mail); Goforth v. Bradshaw , 296 S.W.3d 849, 851 (Tex. App.—Texarkana 2009, no pet.) (holding expert reports and CVs sent by regular mail within statutory deadline, which defendants acknowledged receiving, were timely served even though statute required the documents to be served through registered or certified mail); Spiegel v. Strother ,

22
Netherland v. Wittnergreen
texapp · 1983 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., Roccaforte v. Jefferson County, 341 S.W.3d 919 (Tex.2011) (holding county officials’ acknowledgement of hand-delivered notice satisfied statute’s “requisite notice” even though statute required notice to be delivered by certified or registered mail); Goforth v. Bradshaw, 296 S.W.3d 849, 851 (Tex.App.-Texarkana 2009, no pet.) (holding expert reports and CVs sent by regular mail within statutory deadline, which defendants acknowledged receiving, were timely served even though statute required the documents to be served through registered or certified mail); Spiegel v. Strother, 262 S.

2011See, e.g. , Roccaforte v. Jefferson County , 341 S.W.3d 919 (Tex. 2011) (holding county officials’ acknowledgement of hand-delivered notice satisfied statute’s “requisite notice” even though statute required notice to be delivered by certified or registered mail); Goforth v. Bradshaw , 296 S.W.3d 849, 851 (Tex. App.—Texarkana 2009, no pet.) (holding expert reports and CVs sent by regular mail within statutory deadline, which defendants acknowledged receiving, were timely served even though statute required the documents to be served through registered or certified mail); Spiegel v. Strother ,

22
Goforth v. Bradshawgreen
texapp · 2009 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011See, e.g., Roccaforte v. Jefferson County, 341 S.W.3d 919 (Tex.2011) (holding county officials’ acknowledgement of hand-delivered notice satisfied statute’s “requisite notice” even though statute required notice to be delivered by certified or registered mail); Goforth v. Bradshaw, 296 S.W.3d 849, 851 (Tex.App.-Texarkana 2009, no pet.) (holding expert reports and CVs sent by regular mail within statutory deadline, which defendants acknowledged receiving, were timely served even though statute required the documents to be served through registered or certified mail); Spiegel v. Strother, 262 S.

2011See, e.g. , Roccaforte v. Jefferson County , 341 S.W.3d 919 (Tex. 2011) (holding county officials’ acknowledgement of hand-delivered notice satisfied statute’s “requisite notice” even though statute required notice to be delivered by certified or registered mail); Goforth v. Bradshaw , 296 S.W.3d 849, 851 (Tex. App.—Texarkana 2009, no pet.) (holding expert reports and CVs sent by regular mail within statutory deadline, which defendants acknowledged receiving, were timely served even though statute required the documents to be served through registered or certified mail); Spiegel v. Strother ,

22
City of San Antonio v. Johnsongreen
texapp · 2003 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010Johnson, 103 S.W.3d 639, 642 (Tex. App.—San Antonio 2003, pet. den.).

2010Johnson, 103 S.W.3d 639, 642 (Tex.App.-San Antonio 2003, pet. den.).

22
Star Houston, Inc. v. Kundakgreen
texapp · 1992 · cited in 2 Texas opinions naming this issue, 2007–2007
2 sentences

2007Star Houston Inc. v. Kundak, 843 S.W.2d 294, 297 (Tex. App.—Houston [14th Dist.] 1992, no writ).

2007Star Houston Inc. v. Kundak , 843 S.W.2d 294, 297 (Tex. App.--Houston [14th Dist.] 1992, no writ).

22
Emeritus Corp. v. Highsmithgreen
texapp · 2006 · cited in 3 Texas opinions naming this issue, 2006–2022
2 sentences

2022In McWashington, we cited an opinion from the San Antonio Court of Appeals, in which the court reasoned that, if abatement under section 74.051 tolled the 120-day period, “a plaintiff would in fact be rewarded with additional time for the filing of his report by his failure to comply with the statutory notice requirement.” Emeritus Corp. v. Highsmith, 211 S.W.3d 321, 329 (Tex. App.—San Antonio 2006, pet. denied) (internal quotation omitted).

2016Without deciding whether the plaintiff effectively abated the case, the court held that “an abatement of the proceedings under Section 74.052(a) does not toll or extend the 120-day period for filing an expert report[,]” id. (citing Emeritus, 211 S.W.3d at 327 ), and echoed the concerns expressed by the Emeritus and Hagedorn courts that to hold otherwise would reward the plaintiff with additional time to comply with Chapter 74’s expert report deadline by his failure to comply with the statutory notice requirement.

13
Hash v. Hinesgreen
texapp · 1990 · cited in 2 Texas opinions naming this issue, 1992–1993
2 sentences

1993Id.

1993Id.

12
Sunshine Datsun, Inc. v. Ramseygreen
texapp · 1984 · cited in 2 Texas opinions naming this issue, 1990–1992
2 sentences

1992Hash v. Hines, 796 S.W.2d 312, 315 (Tex.App.—Amarillo 1990, writ granted); Sunshine Datsun, Inc. v. Ramsey, 680 S.W.2d 652, 655 (Tex.App.—Amarillo 1984, no writ).

1990Id.

12
Prairie View A&M University v. Diljit K. Chathagreen
tex · 2012 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025Prairie View A&M Univ. v. Chatha, 381 S.W.3d 500, 515 (Tex. 2012) (“[A] statutory prerequisite to suit, 4 whether administrative (such as filing a charge of discrimination) or procedural (such as timely filing a lawsuit) is jurisdictional when the defendant is a governmental entity.”); State v. Navarrette, 656 S.W.3d 681 , 691 (Tex. App.—El Paso 2022, no pet.) (“One jurisdictional prerequisite to suit under the [TTCA] is compliance with the statutory notice requirement.”).

11
Freedom Communications, Inc. v. Coronadogreen
tex · 2012 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025Univ. of Tex. Rio Grande Valley v. Oteka, 715 S.W.3d 734 , 744 (Tex. 2025) (“[C]ourts always have the duty to ensure that subject-matter jurisdiction—their own and that of the lower courts—is secure.”) (citing S.C. v. M.B., 650 S.W.3d 428 , 449 (Tex. 2022)); Freedom Communications, Inc. v. Coronado, 372 S.W.3d 621, 624 (Tex. 2012) (“[W]e must consider our jurisdiction, even if that consideration is sua sponte.”).

11
Edgar L. Hull, Jr. v. South Coast Catamarans, L.P., Oguz Aksan, Individually, Aksano Catamarans, LLC and James Babcockgreen
texapp · 2011 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019See 365 S.W.3d 35, 44 (Tex. App.—Houston [1st Dist.] 2011, pet. denied) (“Failure to notify the seller of the breach, thereby allowing the seller an opportunity to cure, bars recovery on the basis of breach of warranty.”).

11
University of Texas Southwestern Medical Center at Dallas v. Estate of Arancibia Ex Rel. Vasquez-Arancibiagreen
tex · 2010 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See Carbajal, 324 S.W.3d at 539 ; Simons, 140 S.W.3d at 345 ; Cathey, 900 S.W.2d at 341 .

11
Jose Carreras, M.D., P.A. v. Marroquingreen
tex · 2011 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See Carreras, 339 S.W.3d at 74 ; see also Nicholson v. Shinn, No. 01-07-00973-CV, 2009 WL 3152111 , at *5-6 (Tex.App.Houston [1st Dist.] Oct. 1, 2009, no pet.) *252 (mem. op.) (holding that notice and authorization were ineffective to toll statute because release failed to include information on plaintiffs physicians for previous five years and portion requiring her to identify her treating physicians was also incomplete).

11
Roethel v. Stategreen
texapp · 2002 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See Roethel, 80 S.W.3d at 282 .

11
Terrence Brent McNeil v. Stategreen
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See McNeil v. State, No. 01-13-00234-CR, 2014 WL 6601514, at *5 (Tex. App.—Houston [1st Dist.] Nov. 20, 2014, no pet. h.). 4 Miller’s second argument relies on the failure to comply with the statutory-notice requirement.

11
Moreno v. Brittany Square Associates, L.P.green
texapp · 1995 · cited in 1 Texas opinions naming this issue, 1999–1999
2 sentences

1999See Moreno , 899 S.W.2d at 262-63 .

1999See Moreno , 899 S.W.2d at 262-63 .

11
HOW Insurance Co. v. Patriot Financial Services of Texas, Inc.green
texapp · 1990 · cited in 1 Texas opinions naming this issue, 1995–1995
2 sentences

1995Servs. , 786 S.W.2d 533, 537 (Tex. App.--Austin 1990, writ denied) (under the Texas Deceptive Trade Practices Act--Consumer Protection Act ("DTPA"), notice must be in writing and must meet the specific requirements of the statute). (4) In HOW Insurance we held that the burden of pleading and proving compliance with the statutory notice requirement is on the party seeking recovery.

1995Id.

11
Ex Parte Boylegreen
texapp · 1976 · cited in 1 Texas opinions naming this issue, 1987–1987
1 sentence

1987Ex parte Boyle, 545 S.W.2d 25, 27 (Tex.Civ.App. — Houston [1st Dist.] 1976, no writ).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (16)

CaseCitedYears
University of Texas Southwestern Medical Center v. Loutzenhiser red
tex · 2004
2 sentences

2015If two-plus time, something Loutzenhiser held should be raised “as years qualifies as “timely asserted” or “as soon as possible”— soon as possible” since the statutory purpose is to avoid at least in the context of a statutory notice requirement litigation altogether. 140 S.W.3d at 360 . commanding action—then these phrases have been drained Section 89.0041 may not be a prerequisite to bringing of all meaning. 26 Indeed, the only thing the County “timely suit, but it is a postrequisite to maintaining suit.

2015If two-plus time, something Loutzenhiser held should be raised “as years qualifies as “timely asserted” or “as soon as possible”— soon as possible” since the statutory purpose is to avoid at least in the context of a statutory notice requirement litigation altogether. 140 S.W.3d at 360 . commanding action—then these phrases have been drained Section 89.0041 may not be a prerequisite to bringing of all meaning. 26 Indeed, the only thing the County “timely suit, but it is a postrequisite to maintaining suit.

32011–2015
Cathey v. Booth green
tex · 1995
2 sentences

2018Id. case-ids="10008337" index="173" url="https://cite.case.law/sw2d/900/339/#p341"> at 340-41 (access to medical records did not convey to the hospital its possible culpability as required to satisfy the purpose of the statutory notice requirement).

2016See Carbajal, 324 S.W.3d at 539 ; Simons, 140 S.W.3d at 345 ; Cathey, 900 S.W.2d at 341 .

22016–2018
Lee v. Fenwick green
texapp · 1995
2 sentences

2002Fenwick , 907 S.W.2d 88 (Tex.App.-Eastland 1995, writ denied), appellees argued that notice to appellants' attorney satisfied a statutory notice requirement that "defendant receive written notice" of a claim and that prejudgment interest began to accrue on the date the attorney received notice.

2002In Lee v. Fenwick, 907 S.W.2d 88 (Tex. App.-Eastland 1995, writ denied), appellees argued that notice to appellants’ attorney satisfied a statutory notice requirement that “defendant receive written notice” of a claim and that prejudgment interest began to accrue on the date the attorney received notice.

22002–2002
Thomas v. Ray green
tex · 1994
1 sentence

2025P. 21a(a) (providing “[m]ethods of [s]ervice” for “[e]very notice required by these rules, and every pleading, plea, motion, or other form of request required to be served under Rule 21 [i.e., ‘[e]very pleading, plea, motion, or application to the court for an order . . . unless presented during a hearing or trial’], other than the citation to be served upon the filing of a cause of action and except as otherwise expressly provided in these rules”). 4 Although at the trial court hearing Mohrman cited Thomas v. Ray, 889 S.W.2d 237 (Tex. 1994) as holding that 9 at 691 (“One jurisdictional prereq

12025–2025
Joy Worsdale, Individually and as the Personal Representative of the Estate of Scott Worsdale v. the City of Killeen, Texas green
tex · 2019
1 sentence

2021Worsdale, 578 S.W.3d at 62 .

12021–2021
Texas Department of Criminal Justice v. Simons green
tex · 2004
1 sentence

2016See Carbajal, 324 S.W.3d at 539 ; Simons, 140 S.W.3d at 345 ; Cathey, 900 S.W.2d at 341 .

12016–2016
Hines v. Hash green
tex · 1993
1 sentence

2016Code Ann. § 541.156 ; Hines, 843 S.W.2d at 469 .

12016–2016
Estate of Regis v. Harris County Hospital District green
texapp · 2006
1 sentence

2016Without deciding whether the plaintiff effectively abated the case, the court held that “an abatement of the proceedings under Section 74.052(a) does not toll or extend the 120-day period for filing an expert report[,]” id. (citing Emeritus, 211 S.W.3d at 327 ), and echoed the concerns expressed by the Emeritus and Hagedorn courts that to hold otherwise would reward the plaintiff with additional time to comply with Chapter 74’s expert report deadline by his failure to comply with the statutory notice requirement.

12016–2016
City of Dallas v. Crownrich green
texapp · 1974
11980–1980
Westwood Development Company v. City of Abilene neutral
texapp · 1954
1 sentence

1980In support of its position, the city primarily relies on City of Lubbock v. Stubbs, 160 Tex. Ill, 327 S.W.2d 411 (1959); White v. City of Dallas, 517 S.W.2d 344 (Tex.Civ.App.—Dallas 1974, no writ); City of Dallas v. Crownrich, 506 S.W.2d 654 (Tex.Civ.App.—Tyler 1974, writ ref’d n.r.e.); Huguley v. Board of Adjustment, 341 S.W.2d 212 (Tex.Civ.App.—Dallas 1960, no writ); Westwood Development Company v. City of Abilene, 273 S.W.2d 652 (Tex.Civ.App.—Eastland 1954, writ ref’d n.r.e.); City of Dallas v. Meserole Bros., 164 S.W.2d 564 (Tex.Civ.App.—Dallas 1942, writ ref’d w.o.m.); and City of Dallas

11980–1980
City of Dallas v. Meserole green
texapp · 1941
11980–1980
City of Lubbock v. Stubbs green
tex · 1959
11980–1980
Huguley v. Board of Adjustment of City of Dallas green
texapp · 1960
11980–1980
White v. City of Dallas green
texapp · 1974
11980–1980
City of Dallas v. Meserole Bros. green
texapp · 1942
11980–1980
Texas Employment Commission v. Todd Shipyards Corp. green
texapp · 1953
11953–1953

Statutes the citing opinions construe

TX § Tex. Loc. Gov't Code § 89.0041 (3) USC § 42u.s.c.1983 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NY 110 (1931–2026) TX 38 (1953–2025) IL 34 (1975–2023) FL 32 (1954–2024) MI 30 (1980–2025) CA 29 (1946–2026) IN 25 (1975–2025) CT 22 (1983–2022) MD 20 (2000–2020) WA 15 (1929–2020) CO 14 (1982–2025) UT 13 (1988–2026) NC 12 (1991–2026) KS 10 (1994–2022) ID 10 (1967–2021) OH 10 (1996–2025) TN 10 (1991–2017) GA 10 (1937–2023) DC 9 (1978–2010) ME 9 (1930–2021) MS 8 (2002–2026) MA 8 (1979–2026) MN 8 (1941–2010) OR 7 (1990–2017) PA 7 (1927–2026) WI 7 (1881–2019) VA 6 (1991–2026) MO 6 (1977–2022) NM 6 (1980–2012) NJ 6 (1974–2012) MT 5 (1978–2001) NE 5 (1921–1987) IA 5 (1984–2022) ND 5 (2012–2023) RI 4 (1999–2006) SC 4 (2001–2013) OK 3 (1994–2015) NH 2 (1988–2003) AL 2 (1989–2007) NV 2 (1973–2018) AZ 2 (1959–1988) AR 2 (1985–2016)

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.

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