118 Texas opinions name it 5 courts 1878–2025 10 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 |
|---|---|---|
Mata v. Stategreen2 sentences2025As the Court of Criminal Appeals recognized in Mata, direct appeal records are “usually undeveloped and inadequately reflective of the reasons for defense counsel’s actions at trial.” 226 S.W.3d at 430 . 2022As a threshold matter, “a reviewing court on direct appeal will rarely be able to fairly evaluate the merits of an ineffective-assistance claim because the record on direct appeal is usually undeveloped and inadequately 6 The undisputed and stipulated record reflects that Jones was 16 at the time of the alleged offense and 26 at the time of the hearing to transfer based upon the complaining witness’ outcry to his mother not made until well after Jones’ eighteenth birthday. –15– reflective of the reasons for defense counsel’s actions at trial.” Mata v. State, 226 S.W.3d 425, 430 (Tex. Crim. | 19 | 21 |
Tong v. Stategreen2 sentences2015Tong v. State, 25 S.W.3d 707, 714 (Tex. Crim. 2015Tong v. State, 25 S.W.3d 707 , 714 27 (Tex. Crim. | 4 | 5 |
Thompson v. Stategreen2 sentences2019Thompson, 9 S.W.3d at 813–14; Busby, 990 S.W.2d at 269 . “[T]he record on direct appeal is usually undeveloped and inadequately reflective of the reasons for defense counsel’s actions at trial.” Mata v. 7 State, 226 S.W.3d 425, 430 (Tex. Crim. 2008Mata , 226 S.W.3d, at 430 ("the record on direct appeal is usually undeveloped and inadequately reflective of the reasons for defense counsel's actions at trial."); Bone , 77 S.W.3d, at 833 ("[u]nder normal circumstances, the record on direct appeal will not be sufficient to show that counsel's representation was so deficient and so lacking in tactical or strategic decisionmaking as to overcome the presumption that counsel's conduct was reasonable and professional."); Thompson , 9 S.W.3d, at 813-14 ("[i]n the majority of instances, the record on direct appeal is simply undeveloped and cannot a | 2 | 3 |
Duren v. Stategreen2 sentences2023See Duren v. State, 87 S.W.3d 719 , 733– 34 (Tex. App.—Texarkana 2002, no pet.); see also Young, 991 S.W.2d at 837–38. 2020See Duren v. State, 87 S.W.3d 719 , 733–34 (Tex. App.— Texarkana 2002, no pet.); see also Young, 991 S.W.2d at 837–38. | 2 | 2 |
Salinas v. Stategreen2 sentences2019App. 2007); Salinas v. State, 163 S.W.3d 734, 740 (Tex. Crim. 2019App. 2007); Salinas v. State, 163 S.W.3d 734, 740 (Tex. Crim. | 2 | 2 |
Commissioner v. Sullivangreen2 sentences2006Exemptions are matters of legislative “grace.” Commissioner of Internal Revenue v. Sullivan, 356 U.S. 27, 28 (1958). 2006Exemptions are matters of legislative "grace." Commissioner of Internal Revenue v. Sullivan , 356 U.S. 27, 28 (1958). | 2 | 2 |
Lassiter v. Rotogravure Committee, Inc.green2 sentences2006See Lassiter v. Rotogravure Comm., Inc., 727 S.W.2d 8, 10 (Tex.App.Dallas 1986, writ ref'd n.r.e.). 2006See Lassiter v. Rotogravure Comm., Inc., 727 S.W.2d 8, 10 (Tex.App.-Dallas 1986, writ ref'd n.r.e.). | 2 | 2 |
Matter of Honsakergreen2 sentences1978Without repeating the order in this case, it is noted that it is more specific than the order contained in Matter of Honsaker, 539 S.W.2d 198 at 200 (Tex. Civ.App.Dallas 1976, writ ref'd n. r. e.). 1978Without repeating the order in this case, it is noted that it is more specific than the order contained in Matter of Honsaker, 539 S.W.2d 198 at 200 (Tex.Civ.App.—Dallas 1976, writ ref’d n. r. e.). | 2 | 2 |
In Re JRCgreen2 sentences1977C., 522 S.W.2d 579, 583 (Tex.Civ.App.Texarkana 1975, writ ref'd n. r. e.), relating to the requirement, found in § 54.02(h) of the Family Code, that where a juvenile court "waives" its jurisdiction and certifies a child for trial as an adult, the order state specifically the reasons for the waiver. 1977C., 522 S.W.2d 579, 583 (Tex.Civ.App.—Texarkana 1975, writ ref’d n. r. e.), relating to the requirement, found in § 54.02(h) of the Family Code, that where a juvenile court “waives” its jurisdiction and certifies a child for trial as an adult, the order state specifically the reasons for the waiver. | 2 | 2 |
Stiles v. Resolution Trust Corp.green2 sentences2015See Stiles v. Resolution Trust Corp., 867 S.W.2d 24, 26 (Tex. 1993) (“The effect of the 1971 and 1978 changes . . . is to unequivocally restrict the trial court’s ruling to issues raised in the motion, response, and any subsequent replies . . . . [W]e believe that the reasons for the rule in the trial court apply equally in the appellate court . . . .”). 7 Similarly, to the extent the Court may determine that Appellant raises any issue as to the failure of the district court to order discovery, that issue was waived when Appellant failed to file a verified motion for continuance. 2005The Stiles Court held that this restricts the “trial court’s ruling to issues raised in the motion, response, and any subsequent replies,” and that “[t]hough the rule does not expressly preclude an appellate court from affirming a summary judgment on grounds *876 not raised in the trial court, we believe that the reasons for the rule in the trial court apply equally in the appellate court.” Stiles, 867 S.W.2d at 26 ,. | 1 | 4 |
Blake v. Stategreen1 sentence2025We first conclude that—regardless of whether one agrees with Lanford—the decision is entirely defensible from a legal standpoint, and so, is not “flawed.” Lanford cited our seminal case on statutory construction—Boykin57—and purported to follow it—looking at the plain meaning of the statutory text and resorting to extratextual factors only after finding the language to be ambiguous.58 Lanford did not spend much time deciding that the statute was “classically ambiguous,” but it had previously recited the parties’ arguments, and the combination of those arguments do seem to suggest that the stat | 1 | 1 |
State v. Baldemar Chaveragreen1 sentence2024“The best evidence rule rests on the fact that a document is a more reliable, complete, and accurate source of information as to its contents and meaning than anyone’s description.” State v. Chavera, 386 S.W.3d 334, 337 (Tex. App.—San Antonio 2012, no pet.) (“One of the reasons the rule was developed at common-law is because parol testimony regarding the content of a writing is susceptible to human error.”). | 1 | 1 |
Randol Mill Pharmacy v. Millergreen1 sentence2024See Randol Mill Pharmacy v. Miller, 465 S.W.3d 612, 617 (Tex. 2015) (citations omitted). | 1 | 1 |
Powell v. Stategreen1 sentence2022“Texas law allows individuals to be charged as a party to an offense and to be held criminally responsible for the conduct of another when that individual acts in concert with another person in committing an offense.” Powell v. State, 194 S.W.3d 503, 506 (Tex. Crim. | 1 | 1 |
Young v. Stategreen1 sentence2020See Duren v. State, 87 S.W.3d 719 , 733–34 (Tex. App.— Texarkana 2002, no pet.); see also Young, 991 S.W.2d at 837–38. | 1 | 1 |
| Goodspeed v. Stategreen | 1 | 1 |
| Bekendam, Stephanie Lynngreen | 1 | 1 |
| Gutierrez v. Collinsgreen | 1 | 1 |
| R----E----M v. Stategreen | 1 | 1 |
| Ackermann v. Vordenbaumgreen | 1 | 1 |
| cluster 17242green | 1 | 1 |
| Lopez v. Stategreen | 1 | 1 |
| Strickland v. Washingtongreen | 1 | 1 |
| Mitchell v. Stategreen | 1 | 1 |
| Clark v. Jenkinsgreen | 1 | 1 |
| San Antonio Credit Union v. O'CONNORgreen | 1 | 1 |
| Vista Chevrolet, Inc. v. Barrongreen | 1 | 1 |
| Perdue, Brackett, Flores, Utt & Burns v. Linebarger, Goggan, Blair, Sampson & Meeks, L.L.P.green | 1 | 1 |
| 5-State Helicopters, Inc. v. Coxgreen | 1 | 1 |
| Englund v. Stategreen | 1 | 1 |
| Johnson v. Stategreen | 1 | 1 |
| Bone v. Stategreen | 1 | 1 |
| First Federal Savings & Loan Ass'n of Dallas v. Sharpgreen | 1 | 1 |
| Delrio v. Stategreen | 1 | 1 |
| Christopher Columbus Cooper v. O.A. Brookshire, Sheriff of Ector County, Texasgreen | 1 | 1 |
| Casanova v. Duboisgreen | 1 | 1 |
| Manuel Lewis v. Richmond City Police Department, Director of Public Safety, City Managergreen | 1 | 1 |
| cluster 606747green | 1 | 1 |
| Rowland W. Dory v. Burton T. Ryan, Jr., Assistant District Attorney, Nassau County Robert Andersongreen | 1 | 1 |
| Joe J. Richard v. Dr. Edward Ray, Jr. Samaritan Hospital, A/K/A Columbia Hospital Lexingtongreen | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Jackson v. State
green
2 sentences2021Jackson, 877 S.W.2d at 772 . “[A] reviewing court on direct appeal will rarely be able to fairly evaluate the merits of an ineffective-assistance claim because the record on direct appeal is usually undeveloped and inadequately reflective of the reasons for defense counsel’s actions at trial.” Mata v. State, 226 S.W.3d 425, 430 (Tex. Crim. 2021Jackson, 877 S.W.2d at 772 . “[A] reviewing court on direct appeal will rarely be able to fairly evaluate the merits of an ineffective-assistance claim because the record on direct appeal is usually undeveloped and inadequately reflective of the reasons for defense counsel’s actions at trial.” Mata v. State, 226 S.W.3d 425, 430 (Tex. Crim. | 4 | 1995–2021 |
Moon, Cameron
red
2 sentences2018Id. at 49 . 2017Id. at 49 . | 3 | 2017–2018 |
National Medical Enterprises, Inc. v. Godbey
green
2 sentences2003Godbey , 924 S.W.2d at 132 . 2003Godbey, 924 S.W.2d at 132 . | 2 | 2003–2003 |
Port Arthur Housing Co. v. City of Port Arthur
green
2 sentences1986The rationale behind the requirement was twofold: (1) to protect the city's water mains from contamination, and (2) to preserve the system's water pressure and supply. 181 S.W.2d at 1020 . 1986The rationale behind the requirement was twofold: 111)to protect the city's water mains from contamination. and (2) to preserve the system’s water pressure and supply. 181 S.W.2d at 1020 . | 2 | 1986–1986 |
Albrecht v. State
green
2 sentences1979The reasons for this rule have been stated in Albrecht v. State, 486 S.W.2d 97 (Tex.Cr.App.1972): “Limitations on the admissibility of evidence of an accused’s prior criminal conduct are imposed, not because such evidence is without legal relevance to the general issue of whether the accused committed the act charged, but because such evidence is inherently prejudicial, tends to confuse the issues in the case, and forces the accused to defend himself against charges which he had not been notified would be brought against him.” We cannot accept the State’s contention that evidence of the extran 1979The reasons for this rule have been stated in Albrecht v. State, 486 S.W.2d 97 (Tex.Cr.App. 1972): "Limitations on the admissibility of evidence of an accused's prior criminal conduct are imposed, not because such evidence is without legal relevance to the general issue of whether the accused committed the act charged, but because such evidence is inherently prejudicial, tends to confuse the issues in the case, and forces the accused to defend himself against charges which he had not been notified would be brought against him." We cannot accept the State's contention that evidence of the extra | 2 | 1975–1979 |
Bentinck v. Franklie
green
2 sentences1962Bentinck v. Franklin, 38 Tex. 458 ; Stewart v. [Houston & T. 1962Bentinck v. Franklin, 38 Tex. 458 ; Stewart v. [Houston & T. | 2 | 1922–1962 |
Southern Pacific Company v. Haas
neutral
2 sentences1938This Court, as early as 1892, in the case of Southern Pacific Co. v. Haas, 85 Texas 401 , 20 S. W. 586 , speaking through Chief Justice Stayton, in discussing rules relating to applications for writs of error, held that because no motion for rehearing, presenting the questions on which error was asserted, was filed in the Court of Civil Appeals, the application for writ of error was dismissed; and, in discussing the reasons for the rule, said: “The application for writ of error in this casé shows that no motion for rehearing was made in the Court of Civil Appeals, and it further shows that the 1938This Court, as early as 1892, in the case of Southern Pacific Co. v. Haas, 85 Texas 401 , 20 S. W. 586 , speaking through Chief Justice Stayton, in discussing rules relating to applications for writs of error, held that because no motion for rehearing, presenting the questions on which error was asserted, was filed in the Court of Civil Appeals, the application for writ of error was dismissed; and, in discussing the reasons for the rule, said: “The application for writ of error in this casé shows that no motion for rehearing was made in the Court of Civil Appeals, and it further shows that the | 2 | 1937–1938 |
Short v. Wade
neutral
2 sentences1883Wade, 25 Tex., 510 , do not apply under the changed condition of the law, evidenced by the articles of the Revised Statutes referred to. 1883The reasons for the rule excluding such evidence laid down in Short v. Wade, 25 Tex., 510 , do not apply under the changed condition of the law evidenced by the articles of the Eevised Statutes referred to. | 2 | 1883–1883 |
Norton v. State
green
1 sentence2022The reasons for the rule were made clear by the facts in Norton, in which the State requested a PSI and the appellant confessed to the offense to the supervision officer conducting the interview, which, in turn, the State sought to use at trial. 755 S.W.2d at 524-25 . | 1 | 2022–2022 |
Busby v. State
green
1 sentence2019Thompson, 9 S.W.3d at 813–14; Busby, 990 S.W.2d at 269 . “[T]he record on direct appeal is usually undeveloped and inadequately reflective of the reasons for defense counsel’s actions at trial.” Mata v. 7 State, 226 S.W.3d 425, 430 (Tex. Crim. | 1 | 2019–2019 |
Menefield v. State
green
1 sentence2018Because the record is not developed, we will not find defense counsel’s performance deficient unless the challenged conduct was “so outrageous that no competent attorney would have engaged in it.” Id. | 1 | 2018–2018 |
Roberts v. United States Jaycees
green
2 sentences2018Appellant argues that his trial counsel performed deficiently by failing to ask him any questions "pertinent to establishing a record to argue for protection under the First Amendment as an intimate association." See Roberts v. U.S. Jaycees , 468 U.S. 609 , 617-18, 104 S.Ct. 3244 , 82 L.Ed.2d 462 (1984) (noting that "choices to enter into and maintain certain intimate human relationships must be secured against undue *314 intrusion by the State because of the role of such relationships in safeguarding the individual freedom that is central to our constitutional scheme"). 2018Appellant argues that his trial counsel performed deficiently by failing to ask him any questions "pertinent to establishing a record to argue for protection under the First Amendment as an intimate association." See Roberts v. U.S. Jaycees , 468 U.S. 609 , 617-18, 104 S.Ct. 3244 , 82 L.Ed.2d 462 (1984) (noting that "choices to enter into and maintain certain intimate human relationships must be secured against undue *314 intrusion by the State because of the role of such relationships in safeguarding the individual freedom that is central to our constitutional scheme"). | 1 | 2018–2018 |
Bumpass v. Johnson
green
1 sentence2015Strong policies support our practice of adhering to settled See Kaigler, 961 S.W.2d at 275–76 (recognizing that rules of law “unless there exists the strongest reasons for the rule provides harsh results, but emphasizing that chang[e].” Benavides v. Garcia, 290 S.W. 739 , 740–41 (Tex. uniform enforcement “encourage[s] attentiveness to correct Comm'n App.1927, judgm't adopted). | 1 | 2015–2015 |
| Kaigler v. General Electric Mortgage Insurance Corp. green | 1 | 2015–2015 |
| Reyna v. State green | 1 | 2015–2015 |
In the Interest of K.M.S.
green
1 sentence2015See Bekendam, 441 S.W.3d at 300 ; Reyna, 168 S.W.3d at 177-78 ; Martinez, 91 S.W.3d at 336-37 . | 1 | 2015–2015 |
Uniroyal Goodrich Tire Co. v. Martinez
green
1 sentence2015Hussami also complains about the lack of evidence on various “vital fact[s],” such as “any documentary evidence showing that the acknowledgment of privacy practices, a necessary document before rendering service, was signed to 11 See Uniroyal Goodrich Tire, 977 S.W.2d at 334 . 12 See Tex. R. | 1 | 2015–2015 |
| Stults v. State green | 1 | 2013–2013 |
| Hidalgo v. State green | 1 | 2013–2013 |
| Zarate v. Cortinas green | 1 | 2013–2013 |
| Clemens v. McNamee green | 1 | 2013–2013 |
| Union City Body Co., Inc. v. Ramirez green | 1 | 2012–2012 |
| Hernandez v. New York green | 1 | 1998–1998 |
| Johnson v. Kinney green | 1 | 1996–1996 |
| Neal v. Neal green | 1 | 1985–1985 |
| Heath v. Boyd green | 1 | 1985–1985 |
| Ex Parte Morgan green | 1 | 1982–1982 |
| Lancaster Independent School District v. Pinson green | 1 | 1976–1976 |
| Evans v. Evans green | 1 | 1972–1972 |
| Biard v. Tyler Building & Loan Ass'n neutral | 1 | 1972–1972 |
| Davenport v. Lackie green | 1 | 1972–1972 |
| Ellis v. Emil Blum Co. green | 1 | 1972–1972 |
| St. Paul's Sanitarium v. Freeman green | 1 | 1965–1965 |
| Duvall v. Clark green | 1 | 1965–1965 |
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.