conflict rule (Texas) · Go Syfert
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conflict rule in Texas

18 Texas opinions name it 3 courts 1915–2025 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 (8)

CaseFollowedCited
Malcom v. State of Texasgreen
texcrimapp · 1982 · cited in 3 Texas opinions naming this issue, 2017–2020
2 sentences

2020See, e.g., Malcom v. State, 628 S.W.2d 790 , 791–92 (Tex. Crim.

2019See, e.g., Malcom v. State, 628 S.W.2d 790, 791-92 (Tex. Crim.

33
Trautz v. Lempgreen
· 1932 · cited in 2 Texas opinions naming this issue, 1992–1992
2 sentences

1992See Anderson v. Menefee, 174 S.W. 904, 908 (Tex.Civ.App.—Fort Worth 1915, writ ref’d) (“If the will when fairly construed leaves the question [of time of vesting] in doubt, the doubt will be solved in favor of vesting of the title at the earliest possible moment, so as to avoid a conflict with the rule against perpetuities and to uphold the will.”); see also Trautz v. Lemp, 329 Mo. 580 , 46 S.W.2d 135, 139 (1932) (to avoid the effect of the rule against perpetuities, the court held that legal title passed to the testamentary trustees on the date the will became effective, even though the will

1992See Anderson v. Menefee, 174 S.W. 904, 908 (Tex.Civ.App.—Fort Worth 1915, writ ref’d) (“If the will when fairly construed leaves the question [of time of vesting] in doubt, the doubt will be solved in favor of vesting of the title at the earliest possible moment, so as to avoid a conflict with the rule against perpetuities and to uphold the will.”); see also Trautz v. Lemp, 329 Mo. 580 , 46 S.W.2d 135, 139 (1932) (to avoid the effect of the rule against perpetuities, the court held that legal title passed to the testamentary trustees on the date the will became effective, even though the will

22
Anderson v. Menefeegreen
texapp · 1915 · cited in 3 Texas opinions naming this issue, 1964–1992
2 sentences

1992See Anderson v. Menefee, 174 S.W. 904, 908 (Tex.Civ.App.—Fort Worth 1915, writ ref’d) (“If the will when fairly construed leaves the question [of time of vesting] in doubt, the doubt will be solved in favor of vesting of the title at the earliest possible moment, so as to avoid a conflict with the rule against perpetuities and to uphold the will.”); see also Trautz v. Lemp, 329 Mo. 580 , 46 S.W.2d 135, 139 (1932) (to avoid the effect of the rule against perpetuities, the court held that legal title passed to the testamentary trustees on the date the will became effective, even though the will

1967"In this connection it should be noted that the law favors the vesting of estates rather than otherwise; that is, if the will when fairly construed leaves the question in doubt, the doubt will be solved in favor of the vesting of the title at the earliest possible moment, so as to avoid a conflict with the rule against perpetuities and to uphold the will." Anderson v. Menefee, 174 S.W. 904 (Tex. Civ.App., 1915), writ denied.

13
Tober v. Turner of Texas, Inc.green
texapp · 1984 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019The conflict of which standard applies to the dissolution of a temporary injunction arises from the following clash: whether the general rule—that a trial court has broad discretion to alter its interlocutory orders— applies or whether a more tailored rule—which requires a showing of a change of circumstances between the time of the entry of the temporary injunction and a motion seeking its dissolution—should apply in the unique context of temporary injunctions. 15 Those advocating for a rule that vests the trial court with broad discretion to control its interlocutory orders often cite the Au

11
Sands Motel v. Hargravegreen
texapp · 1962 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018See, e.g., Sands Motel, 358 S.W.2d at 674 (stating that Murphree “held that failure to assign the conflict as error in a motion for new trial waived any complaint and precluded a consideration of it on appeal”); Sutton, 405 S.W.2d at 833 (refusing to consider appellants’ conflict argument “since this point was not raised in their motion for new trial”).

11
Sutton v. Reagan & Geegreen
texapp · 1966 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018See, e.g., Sands Motel, 358 S.W.2d at 674 (stating that Murphree “held that failure to assign the conflict as error in a motion for new trial waived any complaint and precluded a consideration of it on appeal”); Sutton, 405 S.W.2d at 833 (refusing to consider appellants’ conflict argument “since this point was not raised in their motion for new trial”).

11
Ramirez v. Stategreen
texapp · 2000 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015See Maya, 932 S.W.2d at 636 (noting that absent an express, voluntary waiver, an actual conflict of interest that hinders the effectiveness of counsel will mandate a new trial). 10 The trial court, though expressly disapproving of the conflict waiver, did not stop counsel from continuing to represent appellant. 11 See Ramirez v. State, 13 S.W.3d 482 , 486–87 (Tex.App.—Corpus Christi 2000, pet. dism’d). 12 See id. at 486 (holding that evidence counsel struggled to “serve two masters” shows that an accused’s defense has been impaired). 13 The trial court explained it agreed with appellant’s posi

2015See Maya, 932 S.W.2d at 636 (noting that absent an express, voluntary waiver, an actual conflict of interest that hinders the effectiveness of counsel will mandate a new trial). 10 The trial court, though expressly disapproving of the conflict waiver, did not stop counsel from continuing to represent appellant. 11 See Ramirez v. State, 13 S.W.3d 482 , 486–87 (Tex.App.—Corpus Christi 2000, pet. dism’d). 12 See id. at 486 (holding that evidence counsel struggled to “serve two masters” shows that an accused’s defense has been impaired). 13 The trial court explained it agreed with appellant’s posi

11
Maya v. Stategreen
texapp · 1996 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015See Maya, 932 S.W.2d at 636 (noting that absent an express, voluntary waiver, an actual conflict of interest that hinders the effectiveness of counsel will mandate a new trial). 10 The trial court, though expressly disapproving of the conflict waiver, did not stop counsel from continuing to represent appellant. 11 See Ramirez v. State, 13 S.W.3d 482 , 486–87 (Tex.App.—Corpus Christi 2000, pet. dism’d). 12 See id. at 486 (holding that evidence counsel struggled to “serve two masters” shows that an accused’s defense has been impaired). 13 The trial court explained it agreed with appellant’s posi

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 (14)

CaseCitedYears
St. Paul Fire & Marine Insurance Co. v. Murphree green
tex · 1962
2 sentences

2018Murphree , 357 S.W.2d at 748 ; see also Esparza , 2005 WL 3477826 , at *2 (noting that Murphree did not consider "whether assigning error in a motion for new trial would be sufficient to preserve error").

1962Murphree, Tex, 357 S.W.2d 744 , 5 Tex.Sup.Ct.Journal 376, the Supreme Court refused to treat a conflict in the jury’s verdict on special issues as fundamental error, and held that failure to assign the conflict as error in a motion for new trial waived any complaint and precluded a consideration of it on appeal.

31962–2018
Landers v. State green
texcrimapp · 2008
1 sentence

2025Landers, 256 S.W.3d at 304-305 .

12025–2025
Valence Operating Co. v. Dorsett green
tex · 2005
1 sentence

2020This construction is consistent with the Provisional Authority’s requirement that “the Grantors and Grantee share equally in any and all proceeds related [to the exercise of the executory rights].” - 13 - 04-18-00610-CV We cannot construe this Provisional Authority as applying to only the executive rights relating to Meader’s one-half mineral interest because that construction would create a conflict with the clause granting Meader one-half of the minerals “and related executory rights and interests associated therewith.” See Hysaw, 483 S.W.3d at 13 ; Dorsett, 164 S.W.3d at 662 .

12020–2020
Hysaw v. Dawkins green
tex · 2016
1 sentence

2020This construction is consistent with the Provisional Authority’s requirement that “the Grantors and Grantee share equally in any and all proceeds related [to the exercise of the executory rights].” - 13 - 04-18-00610-CV We cannot construe this Provisional Authority as applying to only the executive rights relating to Meader’s one-half mineral interest because that construction would create a conflict with the clause granting Meader one-half of the minerals “and related executory rights and interests associated therewith.” See Hysaw, 483 S.W.3d at 13 ; Dorsett, 164 S.W.3d at 662 .

12020–2020
Union Mutual Life Insurance Co. v. Meyer green
tex · 1973
1 sentence

2018In the recent case of [Murphree], the Supreme Court refused to treat a conflict in the jury’s verdict on special issues as fundamental error, and held that failure to assign the conflict as error in a motion for new trial waived any complaint and precluded a consideration of it on appeal.”). 53 We did not hold otherwise in our 1973 opinion in Meyer, 502 S.W.2d at 679 .

12018–2018
Missouri Pacific Railroad v. Whittenburg & Alston green
tex · 1968
1 sentence

2018A few years later, in Duke , we cited Murphree in support of our holding that "it was necessary to file a motion for new trial assigning as error the entry of judgment on conflicting jury findings." 424 S.W.2d at 898 .

12018–2018
Sun Oil Co. v. Massey green
texapp · 1979
1 sentence

2018Sun Oil Co. v. Massey , 594 S.W.2d 125 , 132 (Tex. Civ.

12018–2018
Jackson v. State Office of Administrative Hearings green
tex · 2011
1 sentence

2016Gov’t Servs., 368 S.W.2d at 3 567; Jackson, 351 S.W.3d at 298 .

12016–2016
Government Services Insurance Underwriters v. Jones green
tex · 1963
1 sentence

2016Gov’t Servs., 368 S.W.2d at 3 567; Jackson, 351 S.W.3d at 298 .

12016–2016
Robert M. Gates v. Shell Oil (Shell Offshore, Inc.) v. Total Services, Inc., and Northwest Insurance Co., Intervenors-Appellants green
ca5 · 1987
1 sentence

1993Id.

11993–1993
Feegles v. Slaughter green
texapp · 1915
1 sentence

1964In the ■event of repugnancy, that construction is favored which admits of immediate vesting ■of the entire estate; and when the will, fairly construed, leaves the question in doubt, the doubt will be resolved in favor of the vesting of the title at the earliest possible moment, so as to avoid a conflict with the rule against perpetuities and to uphold the will. 44 Tex.Jur. 737-738, § 172; Jones’ Unknown Heirs v. Dorchester, Tex. Civ.App., 224 S.W. 596 ; Feegles v. Slaughter, Tex.Civ.App., 182 S.W. 10 , err. ref.; Anderson v. Menefee, Tex.Civ.App., 174 S.W. 904 , err. ref. 8.

11964–1964
Jones' Unknown Heirs v. Dorchester green
texapp · 1920
1 sentence

1964In the ■event of repugnancy, that construction is favored which admits of immediate vesting ■of the entire estate; and when the will, fairly construed, leaves the question in doubt, the doubt will be resolved in favor of the vesting of the title at the earliest possible moment, so as to avoid a conflict with the rule against perpetuities and to uphold the will. 44 Tex.Jur. 737-738, § 172; Jones’ Unknown Heirs v. Dorchester, Tex. Civ.App., 224 S.W. 596 ; Feegles v. Slaughter, Tex.Civ.App., 182 S.W. 10 , err. ref.; Anderson v. Menefee, Tex.Civ.App., 174 S.W. 904 , err. ref. 8.

11964–1964
Sun Mutual Insurance v. Roberts, Willis & Taylor Co. green
tex · 1896
1 sentence

1918We are asked to certify the question considered upon the ground that our decision is in conflict with Blythe v. Crump and Scaling v. Bank, supra. We do not think there is such a conflict under the rule announced in Insurance Co. v. Roberts, supra, as to require this court to certify.

11918–1918
Sumpter v. Carter green
ga · 1902
1 sentence

1915See Underhill, on Wills, vol. 2, § 861; Sumpter v. Carter, 115 Ga, 893, 42 S. E. 324 , 60 L.

11915–1915

Where else courts name it

CA 39 (1931–2023) TX 18 (1915–2025) OH 16 (1986–2023) IL 14 (1888–2023) NY 12 (1961–2023) WA 12 (1997–2023) CO 8 (2002–2026) MD 7 (1981–2026) MO 7 (1993–2023) PA 7 (1975–2024) FL 6 (1987–2024) NM 6 (1953–2023) NC 6 (2001–2022) MI 6 (1976–2013) NJ 6 (1978–2025) MN 5 (1990–2016) IA 5 (1918–2022) LA 4 (2000–2009) DC 4 (1982–2016) NV 4 (1980–2017) ID 3 (1962–1991) UT 3 (1990–2024) NE 3 (1992–2016) WI 3 (1984–2014) AK 3 (1967–2019) VA 3 (1891–2018) CT 3 (1997–2016) AL 3 (1984–1999) MA 2 (2015–2025) KS 2 (1903–1999) MS 2 (1998–2006) AZ 2 (1986–2008) ME 2 (1854–1970) VT 2 (2010–2013) SD 2 (2008–2014) IN 2 (1981–2007) KY 2 (1918–2019) AR 2 (1933–2002) GA 2 (2011–2011)

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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