accord and satisfaction doctrine (Texas) · Go Syfert
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accord and satisfaction doctrine in Texas

24 Texas opinions name it 3 courts 1941–2026 5 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 (14)

CaseFollowedCited
Lopez v. Muñoz, Hockema & Reed, L.L.P.green
tex · 2000 · cited in 9 Texas opinions naming this issue, 2003–2026
2 sentences

2026“The accord and satisfaction defense rests upon a contract, express or implied, in which the parties agree to the discharge of an existing obligation by means of a lesser payment tendered and accepted.” Lopez v. Munoz, Hockema & Reed, L.L.P., 22 S.W.3d 857, 863 (Tex. 2000).

2024See Lopez, 22 S.W.3d at 863 (providing that the common law doctrine of accord and satisfaction “rests upon a new contract, express or implied” whereby the parties agree to the discharge of an existing obligation); Ramos, 2023 WL 5115319 , at *4 (providing that the affirmative defense of release requires the moving party to prove the elements of a valid and binding contract); Vandeventer, 101 S.W.3d at 712 (explaining that whether novation has occurred is a question of the parties’ intent).

89
Case Funding Network, L.P. v. Anglo-Dutch Petroleum International, Inc.green
texapp · 2007 · cited in 5 Texas opinions naming this issue, 2009–2026
2 sentences

2026Int’l, Inc., 264 S.W.3d 38 , 51 n.10 (Tex. App.—Houston [1st Dist.] 2007, pet. denied) (noting that a claimant cannot avoid the accord-and- satisfaction defense by modifying the check).

2015Cooke Co., 290 S.W.3d at 304 (section 3.311 does not conflict with the common-law doctrine of accord and satisfaction; rather, the statute is consistent with the doctrine as interpreted by Texas courts); Case Funding Network, L.P. v. Anglo–Dutch Petroleum Intern., Inc., 264 S.W.3d 38, 50 (Tex.App. – Houston [1st Dist.] 2007, pet. denied) (Texas has adopted the Uniform Commercial Code’s provisions on accord and satisfaction, which are consistent with the Texas courts’ recognition of the common law doctrine of accord and satisfaction); see also TEX.BUS.&COM.CODE ANN. § 3.311, cmt. 3 (“Section 3–

45
Milton M. Cooke Co. v. First Bank and Trustgreen
texapp · 2009 · cited in 4 Texas opinions naming this issue, 2010–2023
2 sentences

2015Cooke Co., 290 S.W.3d at 304 (section 3.311 does not conflict with the common-law doctrine of accord and satisfaction; rather, the statute is consistent with the doctrine as interpreted by Texas courts); Case Funding Network, L.P. v. Anglo–Dutch Petroleum Intern., Inc., 264 S.W.3d 38, 50 (Tex.App. – Houston [1st Dist.] 2007, pet. denied) (Texas has adopted the Uniform Commercial Code’s provisions on accord and satisfaction, which are consistent with the Texas courts’ recognition of the common law doctrine of accord and satisfaction); see also TEX.BUS.&COM.CODE ANN. § 3.311, cmt. 3 (“Section 3–

2015Cooke Co., 290 SW.3d at 304 (section 3.311 does not conflict- with the common-law doctrine of accord and satisfaction; rather, the statute is consistent with the doctrine as interpreted by Texas courts); Case Funding Network, L.P. v. Anglo-Dutch Petroleum Intern., Inc., 264 S.W.3d 38, 50 (Tex.App.-Houston [1st Dist.] 2007, pet. denied) (Texas has adopted the Uniform Commercial Code’s provisions. on accord and satisfaction, which are consistent with the Texas courts’ recognition of the common law doctrine of accord and satisfaction); see also TexBus. & Com.Code Ann. § 3.311, cmt. 3 (“Section 3

34
World Help v. Leisure Lifestyles, Inc.green
texapp · 1998 · cited in 2 Texas opinions naming this issue, 2009–2009
2 sentences

2009Case Funding Network, L.P. v. Anglo-Dutch Petroleum Intern., Inc . 264 S.W.3d 38, 50 (Tex. App.--Houston [1st Dist.] 2007, pet. denied); World Help v. Leisure Lifestyles, Inc . 977 S.W.2d 662, 679-80 (Tex. App.--Fort Worth, 1998, pet. denied); see Tex. Bus. & Com.

2009Case Funding Network, L.P. v. Anglo-Dutch Petroleum Intern., Inc. 264 S.W.3d 38, 50 (Tex.App.-Houston [1st Dist.] 2007, pet. denied); World Help v. Leisure Lifestyles, Inc., 977 S.W.2d 662, 679-80 (Tex.App.-Fort Worth 1998, pet. denied); see Tex. Bus. & Com.Code Ann. § 3.311, cmt. 3 (“Section 3-311 is based on a belief that the common law rule produces a fair result and that informal dispute resolution by full satisfaction checks should be encouraged.”). 3.

22
Marton Remodeling v. Jensengreen
utah · 1985 · cited in 2 Texas opinions naming this issue, 1987–1991
2 sentences

1991See Marton Remodeling v. Jensen, 706 P.2d 607, 610 (Utah 1985); Stultz Elec.

1991See Marton Remodeling v. Jensen, 706 P.2d 607, 610 (Utah 1985); Stultz Elec.

22
Katy International, Inc. F/ka/ Emer International, Inc., Mengghui Zhang and Binghua Jiang v. Jinchun Jianggreen
texapp · 2014 · cited in 2 Texas opinions naming this issue, 2022–2025
2 sentences

2025LuxeYard, Inc. v. Klinek, 643 S.W.3d 260 , 266 (Tex. App— Houston [14th Dist.] 2022, no pet.) (citing Katy Int’l v. Jiang, 451 S.W.3d 74, 86 (Tex. App.—Houston [14th Dist.] 2014, pet. denied)).

2022Katy Int’l v. Jiang, 451 S.W.3d 74 . 86 (Tex. App.—Houston [14th Dist.] 2014, pet. denied).

12
Vandeventer v. All American Life & Casualty Co.green
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See Lopez, 22 S.W.3d at 863 (providing that the common law doctrine of accord and satisfaction “rests upon a new contract, express or implied” whereby the parties agree to the discharge of an existing obligation); Ramos, 2023 WL 5115319 , at *4 (providing that the affirmative defense of release requires the moving party to prove the elements of a valid and binding contract); Vandeventer, 101 S.W.3d at 712 (explaining that whether novation has occurred is a question of the parties’ intent).

11
Custom Transit, L.P., Richway Cartage, Inc., and Custom Operations, LLC v. Flatrolled Steel, Inc.green
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014Id.; see also Custom Transit, L.P. v. Flatrolled Steel, Inc., 375 S.W.3d 337, 347 (Tex.App.-Houston [14th Dist.] 2012, pet. denied) (“[F]or this defense to prevail, there must be a dispute and an unmistakable communication to the creditor that tender of the reduced sum is upon the condition that acceptance will satisfy the underlying obligation.” (alteration in original, citation omitted)).

11
Jenkins v. Henry C. Beck Companygreen
tex · 1969 · cited in 1 Texas opinions naming this issue, 2012–2012
1 sentence

2012Beck Co., 449 S.W.2d 454, 455 (Tex.1969)); see also Huang v. Don McGill Toyota, Inc., 209 S.W.3d 674, 681 (Tex.App.-Houston [14th Dist.] 2006, no pet.). “[F]or this defense to prevail, there must be a dispute and an unmistakable communication to the creditor that tender of the reduced sum is upon the condition that acceptance will satisfy the underlying obligation.” Lopez, 22 S.W.3d at 863 .

11
Hong Huang v. Don McGill Toyota, Inc.green
texapp · 2006 · cited in 1 Texas opinions naming this issue, 2012–2012
1 sentence

2012Beck Co., 449 S.W.2d 454, 455 (Tex.1969)); see also Huang v. Don McGill Toyota, Inc., 209 S.W.3d 674, 681 (Tex.App.-Houston [14th Dist.] 2006, no pet.). “[F]or this defense to prevail, there must be a dispute and an unmistakable communication to the creditor that tender of the reduced sum is upon the condition that acceptance will satisfy the underlying obligation.” Lopez, 22 S.W.3d at 863 .

11
Richardson v. Allstate Texas Lloyd'sgreen
texapp · 2007 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010Richardson v. Allstate Tex. Lloyd’s, 235 S.W.3d 863, 865 (Tex. App.—Dallas 2007, no pet.); Kerrville HRH, Inc. v. City of Kerrville, 803 S.W.2d 377, 388 (Tex. App.—San Antonio 1990, writ denied).

11
Kerrville HRH, Inc. v. City of Kerrvillegreen
texapp · 1990 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010Richardson v. Allstate Tex. Lloyd’s, 235 S.W.3d 863, 865 (Tex. App.—Dallas 2007, no pet.); Kerrville HRH, Inc. v. City of Kerrville, 803 S.W.2d 377, 388 (Tex. App.—San Antonio 1990, writ denied).

11
Trevino v. Brookhill Capital Resources, Inc.green
texapp · 1989 · cited in 1 Texas opinions naming this issue, 1991–1991
2 sentences

1991See Trevino, 782 S.W.2d at 281-82 .

1991See Trevino, 782 S.W.2d at 281-82 .

11
Harris v. Rowegreen
tex · 1979 · cited in 1 Texas opinions naming this issue, 1990–1990
1 sentence

1990Harris v. Rowe, 593 S.W.2d 303, 306 (Tex. 1979).

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 (4)

CaseCitedYears
City of Houston v. First City green
texapp · 1992
1 sentence

2006Reinmiller cites City of Houston v. First City, 827 S.W.2d 462 (Tex.App.-Houston [1st Dist.] 1992, writ denied), as authority.

12006–2006
Stultz Electric Works v. Marine Hydraulic Engineering Co. green
me · 1984
2 sentences

1991Stultz, 484 A.2d at 1011 ; see also Tex.Bu[s]. & Com.Code Ann. sec. 1.103 and official comment 1 (Tex.U.

1991Stultz, 484 A.2d at 1011 ; see also Tex.Bu[s]. & Com.Code Ann. sec. 1.103 and official comment 1 (Tex.U.

11991–1991
Air Van Lines, Inc. v. Buster green
alaska · 1983
2 sentences

1991Without any reference to section 1-207, the court applied the common law accord and satisfaction doctrine. [4] We note that in Air Van Lines, Inc. v. Buster, 673 P.2d 774 (Alaska 1983), the court did not hold that the accord and satisfaction doctrine was unaffected by section 1-207; rather, the court held that if section 1-207 applies to a full-payment check, the creditor failed to explicitly reserve its rights.

1991We note that in Air Van Lines, Inc. v. Buster, 673 P.2d 774 (Alaska 1983), the court did not hold that the accord and satisfaction doctrine was unaffected by section 1-207; rather, the court held that if section 1-207 applies to a full-payment check, the creditor failed to explicitly reserve its rights.

11991–1991
Texas & Pacific Railway Co. v. Poe green
tex · 1938
2 sentences

1941Co. v. Poe, 131 Tex. 337 ; 115 S.W.2d 591 .

1941Co. v. Poe, 131 Tex. 337 ; 115 S.W.2d 591 .

11941–1941

Statutes the citing opinions construe

TX § Tex. Prop. Code § 51.003 (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

TX 24 (1941–2026) LA 18 (1937–2003) OH 10 (1989–2023) NY 7 (1904–2023) RI 6 (2001–2011) IL 6 (1891–2026) NC 5 (1985–2017) MO 5 (1970–2003) AL 5 (1926–2007) IA 4 (1986–2017) CT 4 (1999–2003) WA 4 (1899–2009) VA 3 (1989–2004) DE 3 (1995–2009) KY 3 (1991–2008) CA 3 (1934–2024) OK 3 (1994–1996) FL 3 (1980–2022) MS 3 (1993–2019) MA 3 (1841–2025) OR 2 (1983–2008) NM 2 (1993–2016) WI 2 (2019–2021) UT 2 (1994–2024) WV 2 (2002–2011) SC 2 (1998–2005) GA 2 (1968–1978) MI 2 (1917–1980)

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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