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24 Texas opinions name it 3 courts 1968–2026 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 |
|---|---|---|
St. Paul Fire and Marine Ins. Co. v. Confergreen2 sentences2010Co., 439 S.W.2d 824, 828 (Tex. 1969) ("As used in the dual-purpose rule in the phrase `in furtherance of personal or private affairs of the employee,' we think the word `furtherance' connotes the conferring of a benefit on the employee by helping to forward or advance his personal or private affairs...."). [27] 278 S.W.3d 881, 890 (Tex.App.-Austin 2009) (footnotes omitted). [28] 956 S.W.2d 825 (Tex.App.-San Antonio 1997, pet. denied). [29] Id. at 827, 830 ("[A]n injury occurring between work and the business errand would be compensable because the employee has not completed work, while an inju 2010Co., 439 S.W.2d 824, 828 (Tex. 1969) ("As used in the dual-purpose rule in the phrase `in furtherance of personal or private affairs of the employee,' we think the word `furtherance' connotes the conferring of a benefit on the employee by helping to forward or advance his personal or private affairs...."). [27] 278 S.W.3d 881, 890 (Tex.App.-Austin 2009) (footnotes omitted). [28] 956 S.W.2d 825 (Tex.App.-San Antonio 1997, pet. denied). [29] Id. at 827, 830 ("[A]n injury occurring between work and the business errand would be compensable because the employee has not completed work, while an inju | 6 | 6 |
Rose v. Odiornegreen2 sentences2009See Rose v. Odiorne, 795 S.W.2d 210, 213-14 (Tex.App.-Austin 1990, writ denied). [1] The majority suggests that it is improper to address the application of the "continuous coverage principle" because the appellee raises this argument for the first time in this Court on rehearing. 2007Co. v. Hutchinson, 814 S.W.2d 539 (Tex. App.—Austin 1991, no writ) (holding that dual purpose rule did not bar recovery for customer service employee killed in an accident on trip from family reunion to customer’s home); Rose, 795 S.W.2d 210 . 11 It would defeat the legislative scheme to simply label all travel in the direction of home as “inherently personal” and automatically exclude it from coverage under the dual purpose rule. | 3 | 4 |
Leordeanu v. American Protection Insurance Co.green2 sentences2026Orozco, 602 S.W.3d at 397; see Leordeanu, 330 S.W.3d at 248–49. 2020The dual-purpose rule developed under common law “for the distinct situation in which the employee is traveling between work and a place other than home.” Id. at 245 . | 2 | 5 |
Johnson v. Pacific Employers Indemnity Companygreen2 sentences2010Co., 439 S.W.2d 824, 828 (Tex.1969) ("As used in the dual-purpose rule in the phrase ’in furtherance of personal or private affairs of the employee,’ we think the word ‘furtherance’ connotes the conferring of a benefit on the employee by helping to forward or advance his personal or private affairs.... ”). . 278 S.W.3d 881, 890 (Tex.App.-Austin 2009) (footnotes omitted). . 956 S.W.2d 825 (Tex.App.-San Antonio 1997, pet. denied). . 2010Co., 439 S.W.2d 824, 828 (Tex. 1969) ("As used in the dual-purpose rule in the phrase `in furtherance of personal or private affairs of the employee,' we think the word `furtherance' connotes the conferring of a benefit on the employee by helping to forward or advance his personal or private affairs...."). [27] 278 S.W.3d 881, 890 (Tex.App.-Austin 2009) (footnotes omitted). [28] 956 S.W.2d 825 (Tex.App.-San Antonio 1997, pet. denied). [29] Id. at 827, 830 ("[A]n injury occurring between work and the business errand would be compensable because the employee has not completed work, while an inju | 1 | 2 |
County of El Paso, Self-Insured v. Mary Orozcogreen1 sentence2020As noted, the court of appeals did not expressly apply either exclusion, although it did rely in part on a rationale associated with the 12 coming-and-going rule to support its course-and-scope analysis. 545 S.W.3d at 645 (“We see nothing which would distinguish Ruben [Orozco], at the moment of the accident, from any number of other commuters.”). | 1 | 1 |
Yeldell v. Holiday Hills Retirement and Nursing Center, Inc.green2 sentences2014See King Ranch, Inc. v. Chapman, 118 S.W.3d 742, 751 (Tex. 2003). 6 Under the dual purpose doctrine, “[a]n employee in the course of his employment may perform acts of a personal nature that the person might reasonably do for his health, comfort, such as quenching thirst or relieving hunger.” Yeldell v. Holiday Hills Ret. & Nursing Ctr., 701 S.W.2d. 243, 245 (Tex. 1985). “[S]uch acts are considered incidental to the employee’s service and the injuries sustained while doing so arise in the course and scope of his employment and thus compensable.” Id. 11 We conclude that more than a scintilla of 2014See King Ranch, Inc. v. Chapman, 118 S.W.3d 742, 751 (Tex. 2003). 6 Under the dual purpose doctrine, “[a]n employee in the course of his employment may perform acts of a personal nature that the person might reasonably do for his health, comfort, such as quenching thirst or relieving hunger.” Yeldell v. Holiday Hills Ret. & Nursing Ctr., 701 S.W.2d. 243, 245 (Tex. 1985). “[S]uch acts are considered incidental to the employee’s service and the injuries sustained while doing so arise in the course and scope of his employment and thus compensable.” Id. 11 We conclude that more than a scintilla of | 1 | 1 |
King Ranch, Inc. v. Chapmangreen1 sentence2014See King Ranch, Inc. v. Chapman, 118 S.W.3d 742, 751 (Tex. 2003). 6 Under the dual purpose doctrine, “[a]n employee in the course of his employment may perform acts of a personal nature that the person might reasonably do for his health, comfort, such as quenching thirst or relieving hunger.” Yeldell v. Holiday Hills Ret. & Nursing Ctr., 701 S.W.2d. 243, 245 (Tex. 1985). “[S]uch acts are considered incidental to the employee’s service and the injuries sustained while doing so arise in the course and scope of his employment and thus compensable.” Id. 11 We conclude that more than a scintilla of | 1 | 1 |
American Protection Insurance Co. v. Leordeanugreen2 sentences2010Co., 439 S.W.2d 824, 828 (Tex. 1969) ("As used in the dual-purpose rule in the phrase `in furtherance of personal or private affairs of the employee,' we think the word `furtherance' connotes the conferring of a benefit on the employee by helping to forward or advance his personal or private affairs...."). [27] 278 S.W.3d 881, 890 (Tex.App.-Austin 2009) (footnotes omitted). [28] 956 S.W.2d 825 (Tex.App.-San Antonio 1997, pet. denied). [29] Id. at 827, 830 ("[A]n injury occurring between work and the business errand would be compensable because the employee has not completed work, while an inju 2010Co., 439 S.W.2d 824, 828 (Tex. 1969) ("As used in the dual-purpose rule in the phrase `in furtherance of personal or private affairs of the employee,' we think the word `furtherance' connotes the conferring of a benefit on the employee by helping to forward or advance his personal or private affairs...."). [27] 278 S.W.3d 881, 890 (Tex.App.-Austin 2009) (footnotes omitted). [28] 956 S.W.2d 825 (Tex.App.-San Antonio 1997, pet. denied). [29] Id. at 827, 830 ("[A]n injury occurring between work and the business errand would be compensable because the employee has not completed work, while an inju | 1 | 1 |
Soto v. Seven Seventeen HBE Corp.green1 sentence2007“It is the court’s charge, not some other unidentified law, that measures the sufficiency of the evidence when the opposing party fails to object to the charge.” Soto v. Seven Seventeen HBE Corporation, 52 S.W.3d 201, 209-10 (Tex. App.—Houston [14th Dist.] 2000, no. pet.) (quoting Osterberg v. Peca, 12 S.W.2d 31 , 55 (Tex. 2000)). 5 The trial court rejected American Protection’s motion for summary judgment asserting that the dual purpose rule barred Leordeanu’s claim for benefits “because there has been no evidence offered that Ms. Leordeanu would not have gone home (that she would have abando | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Janak v. TEXAS EMPLOYERS'INSURANCE ASSOCIATION
green
2 sentences2009Janak, 381 S.W.2d at 180 ; Tramel v. State Farm Fire & Cas. 2009Janak, 381 S.W.2d at 180 ; Tramel v. State Farm Fire & Cas. | 9 | 1968–2009 |
Wausau Underwriters Insurance Co. v. Potter
green
2 sentences2009If facts raise the dual purpose doctrine for injury incurred during travel, the juryas it was heremust be instructed as to the dual purpose rule. [2] Wausau Underwriters, 807 S.W.2d at 422-23 ; Texas Workers' Comp. 2009If facts raise the dual purpose doctrine for injury incurred during travel, the juryas it was heremust be instructed as to the dual purpose rule. [2] Wausau Underwriters, 807 S.W.2d at 422-23 ; Texas Workers' Comp. | 5 | 2007–2009 |
Aetna Casualty & Surety Co. v. Orgon
green
2 sentences2009Here the question can be rephrased: "If Leordeanu had not planned to drop by the storage unit, would she have cancelled (or not made) the travel?" The answer to this question is more easily seen to be "no" because she concedes that she was going to go home in any event and the route of travel to both the storage unit and her apartment at the time of the injury was the same. [8] The dissent argues that this case is not governed by the dual purpose rule, but by the "continuous coverage" principle applied by the court in Aetna Casualty & Surety Co. v. Orgon, 721 S.W.2d 572 (Tex.App.-Austin 1986, 2009Here the question can be rephrased: "If Leordeanu had not planned to drop by the storage unit, would she have cancelled (or not made) the travel?” The answer to this question is more easily seen to be “no” because she concedes that she was going to go home in any event and the route of travel to both the storage unit and her apartment at the time of the injury was the same. .The dissent argues that this case is not governed by the dual purpose rule, but by the "continuous coverage” principle applied by the court in Aetna Casualty & Surety Co. v. Orgon, 721 S.W.2d 572 (Tex.App.-Austin 1986, wri | 3 | 2009–2009 |
Shelton v. Standard Insurance Company
green
2 sentences2009This case is not akin to Orgon or other cases that have applied the continuous coverage principle such as Shelton v. Standard Insurance Co., 389 S.W.2d 290 (Tex. 1965), and Texas Employers Insurance Ass'n. v. Cobb, 118 S.W.2d 375 (Tex.Civ.App.-El Paso 1938, writ ref'd). 2009This case is not akin to Orgon or other cases that have applied the continuous coverage principle such as Shelton v. Standard Insurance Co., 389 S.W.2d 290 (Tex.1965), and Texas Employers Insurance Ass’n. v. Cobb, 118 S.W.2d 375 (Tex.Civ.App.-El Paso 1938, writ ref'd). | 3 | 2009–2009 |
Texas Employers Ins. Ass'n v. Cobb
green
2 sentences2009This case is not akin to Orgon or other cases that have applied the continuous coverage principle such as Shelton v. Standard Insurance Co., 389 S.W.2d 290 (Tex. 1965), and Texas Employers Insurance Ass'n. v. Cobb, 118 S.W.2d 375 (Tex.Civ.App.-El Paso 1938, writ ref'd). 2009This case is not akin to Orgon or other cases that have applied the continuous coverage principle such as Shelton v. Standard Insurance Co., 389 S.W.2d 290 (Tex.1965), and Texas Employers Insurance Ass’n. v. Cobb, 118 S.W.2d 375 (Tex.Civ.App.-El Paso 1938, writ ref'd). | 3 | 2009–2009 |
Texas Mutual Insurance Company v. Ronald Jerrols
green
1 sentence2015In reversing the trial court’s summary judgment, the court rejected this argument as an expansive characterization of the continuous coverage doctrine33 and, instead, concluded that the proper method to evaluate compensability was the dual purpose doctrine, and then finding conflict resulting in the reversal of summary judgment.34 31 Seabright, 427 S.W.3d at 450 . 32 Jerrols, 385 S.W.3d 619 . 33 Id at 633. 34 Id at 635. 13 CONCLUSION Here, while the Court accurately reflects the required three-step analysis for evaluating compensability in a travel case, the Court’s application of the facts to | 1 | 2015–2015 |
Seabright Insurance Company v. Maxima Lopez, Beneficiary of Candelario Lopez
green
1 sentence2015In reversing the trial court’s summary judgment, the court rejected this argument as an expansive characterization of the continuous coverage doctrine33 and, instead, concluded that the proper method to evaluate compensability was the dual purpose doctrine, and then finding conflict resulting in the reversal of summary judgment.34 31 Seabright, 427 S.W.3d at 450 . 32 Jerrols, 385 S.W.3d 619 . 33 Id at 633. 34 Id at 635. 13 CONCLUSION Here, while the Court accurately reflects the required three-step analysis for evaluating compensability in a travel case, the Court’s application of the facts to | 1 | 2015–2015 |
Employers Casualty Co. v. Hutchinson
green
1 sentence2007Co. v. Hutchinson, 814 S.W.2d 539 (Tex. App.—Austin 1991, no writ) (holding that dual purpose rule did not bar recovery for customer service employee killed in an accident on trip from family reunion to customer’s home); Rose, 795 S.W.2d 210 . 11 It would defeat the legislative scheme to simply label all travel in the direction of home as “inherently personal” and automatically exclude it from coverage under the dual purpose rule. | 1 | 2007–2007 |
Garza v. Alviar
green
1 sentence1991Garza v. Alviar, 395 S.W.2d 821 (Tex.1965). | 1 | 1991–1991 |
Robins Silk Manufacturing Co. v. Consolidated Piece Dye Works
green
1 sentence1973The seminal case on the dual purpose doctrine as applied to causes arising under the workmen’s compensation laws is that of Judge Cardozo in Marks’ Dependents v. Gray, 251 N.Y. 90 , 167 N.E. 181 (1929). 2 But, the examples postulated by Judge Cardozo do not fit our facts; nor, for that matter, do any of the cases mentioned herein or cited by either of the parties fit. | 1 | 1973–1973 |
Claim of Dependents of Marks v. Gray
green
1 sentence1973The seminal case on the dual purpose doctrine as applied to causes arising under the workmen’s compensation laws is that of Judge Cardozo in Marks’ Dependents v. Gray, 251 N.Y. 90 , 167 N.E. 181 (1929). 2 But, the examples postulated by Judge Cardozo do not fit our facts; nor, for that matter, do any of the cases mentioned herein or cited by either of the parties fit. | 1 | 1973–1973 |
Davis v. Argonaut Southwest Insurance Co.
green
1 sentence1972Davis v. Argonaut Insurance Company, 464 S.W.2d 102 (Tex.Sup., 1971). | 1 | 1972–1972 |
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.
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.