primary-jurisdiction doctrine (Texas) · Go Syfert
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primary-jurisdiction doctrine in Texas

21 Texas opinions name it 2 courts 1987–2026 1 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 (13)

CaseFollowedCited
Gregg v. Delhi-Taylor Oil Corp.green
tex · 1961 · cited in 7 Texas opinions naming this issue, 2000–2026
2 sentences

2026We determined that the primary-jurisdiction doctrine did not apply precisely because the questions were “primarily judicial in nature.” Id. at 415 .

2026And “[w]here the issue is one inherently judicial in nature . . . , the courts are not ousted from jurisdiction unless the Legislature, by a valid statute, has explicitly granted exclusive jurisdiction to the administrative body.” Id.

67
Subaru of America, Inc. v. David McDavid Nissan, Inc.green
tex · 2002 · cited in 6 Texas opinions naming this issue, 2008–2026
2 sentences

2026Accordingly, the primary-jurisdiction doctrine currently “arises when a court and an agency have concurrent original jurisdiction over a dispute.” Cash Am., 35 S.W.3d at 18 (emphasis added); see Subaru, 84 S.W.3d at 221 (explaining that this “judicially-created primary jurisdiction doctrine operates to allocate power between courts and agencies when both have authority to make initial determinations in a dispute”).

2011The primary-jurisdiction doctrine allocates power between courts and agencies when both have authority to make initial determinations in a dispute. [2] Subaru of Am. v. David McDavid Nissan, Inc. , 84 S.W.3d 212, 221 (Tex. 2002).

56
Texas Department of Insurance v. Reconveyance Services, Inc.green
texapp · 2007 · cited in 4 Texas opinions naming this issue, 2008–2009
2 sentences

2009Texas Dep't of Ins. v. Reconveyance Servs., Inc., 240 S.W.3d 418, 433 (Tex. App.-Austin 2007, pet. filed); see also Gregg v. Delhi-Taylor Oil Corp., 162 Tex. 26 , 344 S.W.2d 411, 415 (1961) ("Where the issue is one inherently judicial in nature. . ., the courts are not ousted from jurisdiction unless the Legislature, by a valid statute, has explicitly granted exclusive jurisdiction to the administrative body.").

2008Texas Dep’t of Ins. v. Reconveyance Servs., Inc., 240 S.W.3d 418, 483 (Tex. App.-Austin 2007, pet. filed); see also Gregg v. Delhi-Taylor Oil Corp., 162 Tex. 26 , 344 S.W.2d 411, 415 (1961) (“Where the issue is one inherently judicial in nature ..., the courts are not ousted from jurisdiction unless the Legislature, by a valid statute, has explicitly granted exclusive jurisdiction to the administrative body.”).

44
Butnaru v. Ford Motor Co.green
tex · 2002 · cited in 3 Texas opinions naming this issue, 2010–2010
2 sentences

2010See id. at 208-09 (reasoning that the claims “raise a Code construction issue that is within the [Division’s] special competence and expertise” *917 and that the State had an interest “in a uniform interpretation of the Code”).

2010See id. at 208-09 (reasoning that the claims “raise a Code construction issue that is within the [Division’s] special competence and expertise” and that the State had an interest “in a uniform interpretation of the Code”).

33
Biskamp v. GENERAL CRUDE OIL COMPANYgreen
texapp · 1970 · cited in 2 Texas opinions naming this issue, 2000–2000
2 sentences

2000See Gregg v. Delhi-Taylor Oil Corp., 162 Tex. 26 , 344 S.W.2d 411, 411-16 (1961); Magnolia Petroleum Co. v. Railroad Comm’n, 141 Tex. 96 , 170 S.W.2d 189, 190-91 (1943); Biskamp v. General Crude Oil Co., 452 S.W.2d 515, 517 (Tex.Civ.App.—San Antonio 1970, writ ref'd).

2000See Gregg v. Delhi-Taylor Oil Corp. , 344 S.W.2d 411, 411-16 (Tex. 1961); Magnolia Petroleum Co. v. Railroad Comm'n , 170 S.W.2d 189, 190-91 (Tex. 1943); Biskamp v. General Crude Oil Co. , 452 S.W.2d 515, 517 (Tex. Civ.

22
Magnolia Petroleum Co. v. Railroad Commissiongreen
tex · 1943 · cited in 2 Texas opinions naming this issue, 2000–2000
2 sentences

2000See Gregg v. Delhi-Taylor Oil Corp., 162 Tex. 26 , 344 S.W.2d 411, 411-16 (1961); Magnolia Petroleum Co. v. Railroad Comm’n, 141 Tex. 96 , 170 S.W.2d 189, 190-91 (1943); Biskamp v. General Crude Oil Co., 452 S.W.2d 515, 517 (Tex.Civ.App.—San Antonio 1970, writ ref'd).

2000See Gregg v. Delhi-Taylor Oil Corp. , 344 S.W.2d 411, 411-16 (Tex. 1961); Magnolia Petroleum Co. v. Railroad Comm'n , 170 S.W.2d 189, 190-91 (Tex. 1943); Biskamp v. General Crude Oil Co. , 452 S.W.2d 515, 517 (Tex. Civ.

22
Railroad Commission of Texas v. Arco Oil & Gas Co.green
texapp · 1994 · cited in 3 Texas opinions naming this issue, 1998–2001
2 sentences

2001ARCO, 876 S.W.2d at 478 .

2001Id.

13
Pharmaceutical Research and Manufacturers of America v. Walsh, Acting Commissioner, Maine Department of Human Servicesgreen
scotus · 2003 · cited in 1 Texas opinions naming this issue, 2026–2026
1 sentence

2026Rsch. & Mfrs. of Am. v. Walsh, 538 U.S. 644, 673 (2003) (Breyer, J., concurring in part and in the judgment) (enumerating prudential considerations—including “whether preliminary reference of issues to the agency will promote th[e] proper working relationship between court and agency”—that inform the primary-jurisdiction doctrine’s application).

11
Far East Conference v. United Statesgreen
scotus · 1952 · cited in 1 Texas opinions naming this issue, 2026–2026
1 sentence

2026Conf. v. United States, 342 U.S. 570, 575 (1952).

11
Cash America International Inc. v. Bennettgreen
tex · 2000 · cited in 1 Texas opinions naming this issue, 2026–2026
1 sentence

2026Accordingly, the primary-jurisdiction doctrine currently “arises when a court and an agency have concurrent original jurisdiction over a dispute.” Cash Am., 35 S.W.3d at 18 (emphasis added); see Subaru, 84 S.W.3d at 221 (explaining that this “judicially-created primary jurisdiction doctrine operates to allocate power between courts and agencies when both have authority to make initial determinations in a dispute”).

11
Katie Arsberry v. State of Illinoisgreen
ca7 · 2001 · cited in 1 Texas opinions naming this issue, 2026–2026
1 sentence

2026The primary-jurisdiction doctrine thus “allows a court to refer an issue to an agency that knows more about the issue, even if the agency hasn’t been given exclusive jurisdiction to resolve it.” Arsberry v. Illinois, 244 F.3d 558, 563 (7th Cir. 2001) (Posner, J.).

11
Lens Express, Inc. v. Ewaldgreen
texapp · 1995 · cited in 1 Texas opinions naming this issue, 1998–1998
1 sentence

1998Lens Express, Inc. v. Ewald , 907 S.W.2d 64, 71 (Tex. App.--Austin 1995, no writ).

11
Lake Country Estates, Inc. v. Tomangreen
texapp · 1981 · cited in 1 Texas opinions naming this issue, 1992–1992
1 sentence

1992See Lake Country Estates, Inc. v. Toman, 624 S.W.2d 677, 681 (Tex.App.1981, writ ref’d n.r.e.).

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
Marquez v. Screen Actors Guild, Inc. green
scotus · 1998
1 sentence

2026(Indeed, the last time the Court appears to have applied the doctrine at all in a majority opinion was 28 years ago in Marquez v. Screen Actors Guild, Inc., 525 U.S. 33 (1998).) But the Court at least has hinted that the primary-jurisdiction doctrine may have broader application than its original conception.

12026–2026
Forest Oil Corporation, Now Known as Sabine Oil & Gas Corporation v. El Rucio Land and Cattle Company, Inc., San Juanito Land Partnership, Ltd., McAllen Trust Partnership, and James Argyle McAllen green
tex · 2017
1 sentence

2026If there is 8 concurrent jurisdiction, we have said, courts “should allow an administrative agency to initially decide an issue when: (1) an agency is typically staffed with experts trained in handling the complex problems in the agency’s purview; and (2) great benefit is derived from an agency’s uniformly interpreting its laws, rules, and regulations, whereas courts and juries may reach different results under similar fact situations.” Forest Oil, 518 S.W.3d at 429–30.

12026–2026
In Re Southwestern Bell Telephone Co., LP green
tex · 2007
1 sentence

2015Co., L.P., 226 S.W.3d 400 , 403–04 (Tex. 2007) (finding each of these requirements satisfied because the Public Utility Commission “is staffed with experts who routinely consider the validity and enforceability of [telephone] inter- connection agreements” and application of the primary-jurisdiction doctrine would avoid “[c]onflicting jury verdicts and rulings by different courts” in similar situa- tions). 39 B. 1 .

12015–2015
United States v. Western Pacific Railroad green
scotus · 1956
2 sentences

1987The jurisdiction given in APTRA § 12 to the Travis County district courts is an original jurisdiction, and not an “appellate” jurisdiction such as that contemplated by PURA §§ 69 and 85 and AP-TRA § 19, discussed below. 2 Thus, the primary-jurisdiction doctrine applies to litigation brought under APTRA § 12 (such claims being originally cognizable in court by the terms of APTRA § 12), provided the doctrine is applicable under the issues raised and the statutory scheme that applies to the case. 3 See United States v. *670 Western Pacific Railroad, 352 U.S. 59 , 77 S.Ct. 161 , 1 L.Ed.2d 126 (195

1987The jurisdiction given in APTRA § 12 to the Travis County district courts is an original jurisdiction, and not an “appellate” jurisdiction such as that contemplated by PURA §§ 69 and 85 and AP-TRA § 19, discussed below. 2 Thus, the primary-jurisdiction doctrine applies to litigation brought under APTRA § 12 (such claims being originally cognizable in court by the terms of APTRA § 12), provided the doctrine is applicable under the issues raised and the statutory scheme that applies to the case. 3 See United States v. *670 Western Pacific Railroad, 352 U.S. 59 , 77 S.Ct. 161 , 1 L.Ed.2d 126 (195

11987–1987

Statutes the citing opinions construe

TX § Tex. Occ. Code § 801.451 (4) TX § Tex. Occ. Code § 801.457 (4) TX § Tex. Nat. Res. Code § 85.241 (3) TX § Tex. Occ. Code § 2301.002 (3) TX § Tex. Occ. Code § 2301.151 (3) TX § Tex. Occ. Code § 2301.351 (3) TX § Tex. Occ. Code § 2301.476 (3) TX § Tex. Occ. Code § 2301.751 (3) TX § Tex. Occ. Code § 2301.755 (3) TX § Tex. Occ. Code § 2301.803 (3) TX § Tex. Occ. Code § 2301.805 (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 21 (1987–2026) WI 6 (1966–2022) IL 4 (1986–2000) MI 3 (2000–2014) MD 2 (2017–2017)

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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