letter rule (Texas) · Go Syfert
← Texas issues

letter rule in Texas

30 Texas opinions name it 3 courts 1902–2025 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 (10)

CaseFollowedCited
Lee v. Stategreen
texcrimapp · 1977 · cited in 3 Texas opinions naming this issue, 1983–2016
2 sentences

2016Id. at 122-23 .

1983In Lee v. State, 555 S.W.2d 121 (Tex.Cr.App.1977) that judge, as a former prosecuting attorney, wrote a letter to defense counsel relative to a possible plea; he had no personal knowledge of the case but relied upon another State attorney's assessment of the case.

13
Johnson v. Stategreen
texapp · 2011 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See Haas v. State, 494 S.W.3d 819, 823 (Tex. App.—Houston [14th Dist.] 2016, no pet.) (“An appellate court must review the trial court’s ruling in light of what was before the trial court at the time the ruling was made.”). 37 State, No. 12-17-00124-CR, 2018 WL 6321081 , at *3 (Tex. App.—Tyler Dec. 4, 2018, no pet.) (mem. op., not designated for publication) (concluding same where counsel filed two separate motions premised on appellant’s recurring complaints that counsel was failing to communicate with him or spend time on his case); Anderson v. State, No. 02-17-00044- CR, 2018 WL 359635 , at

11
Dallas County v. Gonzalesgreen
texapp · 2006 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See, e.g., Dallas County v. regarding possible discrimination but indicated Gonzales, 183 S.W.3d 94 (Tex.App.-Dallas 2006, that the TCHR could pet. denied).

11
Haas v. Stategreen
texapp · 2016 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See Haas v. State, 494 S.W.3d 819, 823 (Tex. App.—Houston [14th Dist.] 2016, no pet.) (“An appellate court must review the trial court’s ruling in light of what was before the trial court at the time the ruling was made.”). 37 State, No. 12-17-00124-CR, 2018 WL 6321081 , at *3 (Tex. App.—Tyler Dec. 4, 2018, no pet.) (mem. op., not designated for publication) (concluding same where counsel filed two separate motions premised on appellant’s recurring complaints that counsel was failing to communicate with him or spend time on his case); Anderson v. State, No. 02-17-00044- CR, 2018 WL 359635 , at

11
Randy Austin v. Kroger Texas, L.P.green
tex · 2015 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023See generally Austin v. Kroger Texas, L.P., 465 S.W.3d 193, 204 (Tex. 2015) (no need to warn against known danger); Hicks v. Humble Oil & Refin.

11
White, Garcia Glengreen
texcrimapp · 2016 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020App. 2018) (quoting from Ex parte White, 506 S.W.3d 39, 44 (Tex. Crim.

11
Ex parte Kussmaulgreen
texcrimapp · 2018 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020In Prince v. State, this Court held that a prosecutor was “of counsel for the State” if he “participated in any manner in the preparation or investigation of the case.”35 In Metts v. State, we explained that the prosecutor must have “investigated, advised or participated” as counsel in the case, or, stated another way, his “involvement must have arisen to a level of active participation.”36 We surveyed the caselaw relating to Article 30.01 and observed a variety of relatively minor acts that would make a prosecutor qualify as “of counsel” for the State.37 We held that merely signing a jury-wai

11
Alenia Spazio, S.P.A. v. Reidgreen
texapp · 2004 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019See Searcy, 496 S.W.3d at 62 (even considering “voluminous” extent of communications, foreign entity did not purposefully avail itself of Texas’s jurisdiction because its “contacts with Texas were too fortuitous and attenuated”); Alenia Spazio, S.p.A. v. Reid, 130 S.W.3d 201, 213 (Tex. App.—Houston [14th Dist.] 2003, pet. denied) (“[N]umerous telephone and facsimile communications with people in Texas relating to an alleged contract do not establish minimum contacts.”).

11
Jason R. Searcy, as Trustee of the Exempt Assets Trust v. Parex Resources, Inc.green
tex · 2016 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019See Searcy, 496 S.W.3d at 62 (even considering “voluminous” extent of communications, foreign entity did not purposefully avail itself of Texas’s jurisdiction because its “contacts with Texas were too fortuitous and attenuated”); Alenia Spazio, S.p.A. v. Reid, 130 S.W.3d 201, 213 (Tex. App.—Houston [14th Dist.] 2003, pet. denied) (“[N]umerous telephone and facsimile communications with people in Texas relating to an alleged contract do not establish minimum contacts.”).

11
Angela Michelle Harris v. Stategreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018See Harris v. State, 402 S.W.3d 758 , 760–61 & n.2 (Tex. App.—Houston [1st Dist.] 2012, no pet.) (matters involving disclosure and nondisclosure of criminal history record information under Texas Government Code are treated as civil, not criminal).

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 (34)

CaseCitedYears
Garner v. State green
texapp · 1994
2 sentences

2012Garner, 864 S.W.2d at 99 .

2011Garner, 864 S.W.2d at 99 .

22011–2012
Abdygapparova v. State green
texapp · 2007
2 sentences

2009Id.

2009Id.

22009–2009
Calvery v. Calvery green
· 1932
2 sentences

1950They more readily seize hold of any qualifying or super-added words, varying the sense of the technical ./terms in order to make them words of designation, than is done in England.’ ■ “And in Calvery v. Calvery, 122 Tex. 204, 212 , 55 S.W.2d 527, 530 , Justice Sharp, then Commissioner, writing, an opinion adopted by the court, said: ‘It is only when the facts bring a case under the strict letter of the rule that the courts of this state will apply and enforce it.’ “The prevailing inclination has been away from the application of a technical rule and to the ascertainment of the true intention o

1950They more readily seize hold of any qualifying or super-added words, varying the sense of the technical ./terms in order to make them words of designation, than is done in England.’ ■ “And in Calvery v. Calvery, 122 Tex. 204, 212 , 55 S.W.2d 527, 530 , Justice Sharp, then Commissioner, writing, an opinion adopted by the court, said: ‘It is only when the facts bring a case under the strict letter of the rule that the courts of this state will apply and enforce it.’ “The prevailing inclination has been away from the application of a technical rule and to the ascertainment of the true intention o

21948–1950
Gevinson v. Manhattan Construction Co. of Oklahoma green
tex · 1969
1 sentence

2015In Gevinson v. Manhattan Construction Co. of Okl., 449 S.W.2d 458 (Tex. 1969) the Court that “It has been said that one who introduces a document vouches for its accuracy and will not be allowed to impeach or contradict its recitals.” Though Caziers fee affidavit may not meet the formal requirements of judicial estopple, Caziers fee affidavit is some evidence.

12015–2015
Teladoc, Inc. v. Texas Medical Board and Nancy Leshikar, in Her Official Capacity as General Counsel of the Texas Medical Board green
texapp · 2014
1 sentence

2015The court of appeals properly held that the letter was a rule under the APA that bypassed notice-and-comment rulemaking, and is thus invalid under Section 2001.035 of the APA. 453 S.W.3d at 620 .

12015–2015
Ex Parte Lemke green
texcrimapp · 2000
1 sentence

2001"The government may of course, in proper cases, seek to demonstrate that intervening circumstances have so changed the factual premises of its original offer that, with just cause, it would have modified or withdrawn its offer prior to its expiration date.” Ex parte Lemke, 13 S.W.3d at 798 .

12001–2001
Strickland v. Washington green
scotus · 1984
2 sentences

2001The letter was addressed to defense counsel, but the heading read “Dear Leon.” During the hearing on pretrial motions, it was established that the name "Leon" appeared in the heading on the letter to defense counsel by mistake. 3 . 466 U.S. at 687 , 104 S.Ct. at 2064 . 4 .

2001The letter was addressed to defense counsel, but the heading read “Dear Leon.” During the hearing on pretrial motions, it was established that the name "Leon" appeared in the heading on the letter to defense counsel by mistake. 3 . 466 U.S. at 687 , 104 S.Ct. at 2064 . 4 .

12001–2001
Nguyen v. Kim green
texapp · 1999
1 sentence

2000Id. at 154 .

12000–2000
Moreno v. State green
texapp · 1993
2 sentences

1996This led a majority of this Court, sitting en banc, to follow Jones and strictly enforce the letter of rule 40(b)(1) in Moreno v. State, 866 S.W.2d 660 (Tex.App.— Houston [1st Dist.] 1993, no pet.) (holding a general notice of appeal insufficient to allow review of pretrial motions after plea pursuant to agreed plea bargain), albeit reluctantly and with much urging that the Court of Criminal Appeals change the rule.

1996This led a majority of this Court, sitting en banc, to follow Jones and strictly enforce the letter of rule 40(b)(1) in Moreno v. State, 866 S.W.2d 660 (Tex.App.—Houston [1st Dist.] 1993, no pet.) (holding a general notice of appeal insufficient to allow review of pretrial motions after plea pursuant to agreed plea bargain), albeit reluctantly and with much urging that the Court of Criminal Appeals change the rule.

11996–1996
Alfred Ray Bradshaw v. O.L. McCotter Director, Texas Department of Corrections green
ca5 · 1986
1 sentence

1987None of these facts are present in the instant case. [8] We are aware of the decision in Bradshaw v. McCotter, 796 F.2d 100 (5th Cir.1986), which modified the earlier decision, 785 F.2d 1327 .

11987–1987
Alfred Ray Bradshaw v. O.L. McCotter Director, Texas Department of Corrections green
ca5 · 1986
1 sentence

1987None of these facts are present in the instant case. [8] We are aware of the decision in Bradshaw v. McCotter, 796 F.2d 100 (5th Cir.1986), which modified the earlier decision, 785 F.2d 1327 .

11987–1987
Womacks v. Horne neutral
texapp · 1957
1 sentence

1981Rule 434 TRCP; Whited v. Powell, 155 Tex. 210 , 285 S.W.2d 364 ; Womacks v. Home, CCA (Waco) NWH, Tex.Civ.App. 300 S.W.2d 765 ; Lockett v. Redi-Fuel Transport, Inc., CCA (Eastland) NRE, Tex.Civ.App. 558 S.W.2d 902 .

11981–1981
Lockett v. Redi-Fuel Transport, Inc. neutral
texapp · 1977
1 sentence

1981Rule 434 TRCP; Whited v. Powell, 155 Tex. 210 , 285 S.W.2d 364 ; Womacks v. Home, CCA (Waco) NWH, Tex.Civ.App. 300 S.W.2d 765 ; Lockett v. Redi-Fuel Transport, Inc., CCA (Eastland) NRE, Tex.Civ.App. 558 S.W.2d 902 .

11981–1981
Whited v. Powell green
tex · 1956
2 sentences

1981Rule 434 TRCP; Whited v. Powell, 155 Tex. 210 , 285 S.W.2d 364 ; Womacks v. Home, CCA (Waco) NWH, Tex.Civ.App. 300 S.W.2d 765 ; Lockett v. Redi-Fuel Transport, Inc., CCA (Eastland) NRE, Tex.Civ.App. 558 S.W.2d 902 .

1981Rule 434 TRCP; Whited v. Powell, 155 Tex. 210 , 285 S.W.2d 364 ; Womacks v. Home, CCA (Waco) NWH, Tex.Civ.App. 300 S.W.2d 765 ; Lockett v. Redi-Fuel Transport, Inc., CCA (Eastland) NRE, Tex.Civ.App. 558 S.W.2d 902 .

11981–1981
Cox v. State neutral
texcrimapp · 1955
2 sentences

1977This reasoning ignores the spirit of the rule: “The rule of circumstantial evidence applies to all the facts in a case, and not to any fact or set of facts . . . .” Cox v. State, 161 Tex.Cr.R. 421 , 278 S.W.2d 155 (Tex.Cr.App.1955).

1977This reasoning ignores the spirit of the rule: “The rule of circumstantial evidence applies to all the facts in a case, and not to any fact or set of facts . . . .” Cox v. State, 161 Tex.Cr.R. 421 , 278 S.W.2d 155 (Tex.Cr.App.1955).

11977–1977
Benefit Ass'n of Ry. Employees v. O'Gorman neutral
texapp · 1946
2 sentences

1961Employees v. O'Gorman, Tex.Civ.App., 195 S.W.2d 215 , writ ref. n. r. e. It will be noted that the letter of waiver was written within 91 days from the date the construction of the storm sewer began, and that such letter states that the insured had sustained loss not covered under the insurance policy contract.

1961Employees v. O’Gorman, Tex.Civ.App., 195 S.W.2d 215 , writ ref. n. r. e. It will be noted that the letter of waiver was written within 91 days from the date the construction of the storm sewer began, and that such letter states that the insured had sustained loss not covered under the insurance policy contract.

11961–1961
Crist v. Morgan green
texcommnapp · 1922
11948–1948
Brown v. Bryant neutral
texapp · 1897
11948–1948
Peters v. Rice neutral
texapp · 1913
11948–1948
Busha v. Fortson neutral
ca5 · 1940
1 sentence

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

11948–1948
Scott v. Brin neutral
texapp · 1908
2 sentences

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

11948–1948
Lacey v. Floyd green
· 1905
2 sentences

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

11948–1948
Pearce v. Pearce green
· 1911
2 sentences

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

1948In the following cases it was held that the language of the instrument involved in each brought the case within the rule in Shelley’s Case: Busha v. Fortson, 5 Cir., 116 F.2d 325 ; Lacey v. Floyd, 99 Tex. 112 , 87 S.W. 665 ; Crist v. Morgan, Tex.Com.App., 245 S.W. 659 ; Peters v. Rice, Tex.Civ.App., 157 S.W. 1181 , writ refused; Pearce v. Pearce, 104 Tex. 73 , 134 S.W. 210 ; Scott v. Brin, 48 Tex.Civ.App. 500 , 107 S.W. 565 , writ refused; Brown v. Bryant, 17 Tex.Civ.App. 454 , 44 S.W. 399 , writ refused; and Davis v. First Nat.

11948–1948
Pendley v. Berry & Towles green
tex · 1901
11945–1945
Quinn v. Home Owners' Loan Corp. neutral
texapp · 1939
11940–1940
Ferguson v. Sanders green
texapp · 1939
11940–1940
Hamilton v. Booher green
texapp · 1939
11940–1940
Farmers' Seed & Gin Co. v. Brooks green
tex · 1935
11940–1940
Port Iron & Supply Co. v. Casualty Underwriters neutral
texapp · 1938
11940–1940
Wallace v. First National Bank of Paris green
· 1931
11938–1938
Federal Land Bank v. Little green
· 1937
11938–1938
Texas Mexican Railway Co. v. Scott neutral
· 1910
11934–1934
Ætna Life Ins. v. Burnett green
texcommnapp · 1926
11932–1932
San Antonio & Aransas Pass Railway Co. v. Holden neutral
tex · 1900
11902–1902

Where else courts name it

LA 55 (1895–2026) NY 36 (1898–2021) TX 30 (1902–2025) CA 28 (1887–2025) PA 20 (1896–2025) IL 12 (1939–2024) KY 11 (2017–2025) OH 11 (1897–2024) MO 10 (1911–2025) OR 9 (1935–2015) GA 9 (1887–2011) MI 9 (1986–2018) NJ 8 (1969–2019) AL 7 (1886–2024) TN 7 (1948–2007) MN 7 (1909–2015) DC 7 (1980–2013) MA 7 (1897–2023) FL 6 (1885–2016) AZ 6 (1952–2025) IA 5 (1905–2026) OK 5 (1907–2009) UT 5 (1896–2023) MS 5 (1999–2007) MD 5 (1997–2022) VA 4 (2011–2018) AR 4 (1906–2016) CO 4 (1912–1977) ND 4 (1909–2012) NE 4 (1895–1994) KS 4 (1904–2015) CT 3 (1993–2016) SC 3 (2007–2020) WI 2 (1926–1947) WA 2 (2015–2016) NM 2 (1939–2006) WV 2 (1895–1912) MT 2 (1935–2025)

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.

← Caselaw search · G Cite Topics · Brief Check