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

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.

Followed or applied (46)

CaseFollowedCited
Mata v. Stategreen
texcrimapp · 2007 · cited in 21 Texas opinions naming this issue, 2008–2025
2 sentences

2025As 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.

1921
Tong v. Stategreen
texcrimapp · 2000 · cited in 5 Texas opinions naming this issue, 2015–2015
2 sentences

2015Tong v. State, 25 S.W.3d 707, 714 (Tex. Crim.

2015Tong v. State, 25 S.W.3d 707 , 714 27 (Tex. Crim.

45
Thompson v. Stategreen
texcrimapp · 1999 · cited in 3 Texas opinions naming this issue, 2005–2019
2 sentences

2019Thompson, 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

23
Duren v. Stategreen
texapp · 2002 · cited in 2 Texas opinions naming this issue, 2020–2023
2 sentences

2023See 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.

22
Salinas v. Stategreen
texcrimapp · 2005 · cited in 2 Texas opinions naming this issue, 2019–2019
2 sentences

2019App. 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.

22
Commissioner v. Sullivangreen
scotus · 1958 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006Exemptions 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).

22
Lassiter v. Rotogravure Committee, Inc.green
texapp · 1987 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006See 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.).

22
Matter of Honsakergreen
texapp · 1976 · cited in 2 Texas opinions naming this issue, 1978–1978
2 sentences

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.).

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.).

22
In Re JRCgreen
texapp · 1975 · cited in 2 Texas opinions naming this issue, 1977–1977
2 sentences

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.

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.

22
Stiles v. Resolution Trust Corp.green
tex · 1993 · cited in 4 Texas opinions naming this issue, 2005–2015
2 sentences

2015See 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 ,.

14
Blake v. Stategreen
texcrimapp · 1998 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025We 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

11
State v. Baldemar Chaveragreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024“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.”).

11
Randol Mill Pharmacy v. Millergreen
tex · 2015 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See Randol Mill Pharmacy v. Miller, 465 S.W.3d 612, 617 (Tex. 2015) (citations omitted).

11
Powell v. Stategreen
texcrimapp · 2006 · cited in 1 Texas opinions naming this issue, 2022–2022
1 sentence

2022“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.

11
Young v. Stategreen
texcrimapp · 1999 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

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.

11
Goodspeed v. Stategreen
texcrimapp · 2005 · cited in 1 Texas opinions naming this issue, 2015–2015
11
Bekendam, Stephanie Lynngreen
texcrimapp · 2014 · cited in 1 Texas opinions naming this issue, 2015–2015
11
Gutierrez v. Collinsgreen
tex · 1979 · cited in 1 Texas opinions naming this issue, 2015–2015
11
R----E----M v. Stategreen
texapp · 1976 · cited in 1 Texas opinions naming this issue, 2014–2014
11
Ackermann v. Vordenbaumgreen
tex · 1966 · cited in 1 Texas opinions naming this issue, 2014–2014
11
cluster 17242green
· · cited in 1 Texas opinions naming this issue, 2013–2013
11
Lopez v. Stategreen
texcrimapp · 2011 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Strickland v. Washingtongreen
scotus · 1984 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Mitchell v. Stategreen
texcrimapp · 2002 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Clark v. Jenkinsgreen
texapp · 2008 · cited in 1 Texas opinions naming this issue, 2013–2013
11
San Antonio Credit Union v. O'CONNORgreen
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Vista Chevrolet, Inc. v. Barrongreen
texapp · 1985 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Perdue, Brackett, Flores, Utt & Burns v. Linebarger, Goggan, Blair, Sampson & Meeks, L.L.P.green
texapp · 2009 · cited in 1 Texas opinions naming this issue, 2013–2013
11
5-State Helicopters, Inc. v. Coxgreen
texapp · 2004 · cited in 1 Texas opinions naming this issue, 2013–2013
11
Englund v. Stategreen
texcrimapp · 1997 · cited in 1 Texas opinions naming this issue, 2012–2012
11
Johnson v. Stategreen
texapp · 2004 · cited in 1 Texas opinions naming this issue, 2009–2009
11
Bone v. Stategreen
texcrimapp · 2002 · cited in 1 Texas opinions naming this issue, 2008–2008
11
First Federal Savings & Loan Ass'n of Dallas v. Sharpgreen
tex · 1962 · cited in 1 Texas opinions naming this issue, 2006–2006
11
Delrio v. Stategreen
texcrimapp · 1992 · cited in 1 Texas opinions naming this issue, 2006–2006
11
Christopher Columbus Cooper v. O.A. Brookshire, Sheriff of Ector County, Texasgreen
ca5 · 1995 · cited in 1 Texas opinions naming this issue, 2004–2004
11
Casanova v. Duboisgreen
ca1 · 2002 · cited in 1 Texas opinions naming this issue, 2004–2004
11
Manuel Lewis v. Richmond City Police Department, Director of Public Safety, City Managergreen
ca4 · 1991 · cited in 1 Texas opinions naming this issue, 2004–2004
11
cluster 606747green
ca11 · 1993 · cited in 1 Texas opinions naming this issue, 2004–2004
11
Rowland W. Dory v. Burton T. Ryan, Jr., Assistant District Attorney, Nassau County Robert Andersongreen
ca2 · 1993 · cited in 1 Texas opinions naming this issue, 2004–2004
11
Joe J. Richard v. Dr. Edward Ray, Jr. Samaritan Hospital, A/K/A Columbia Hospital Lexingtongreen
ca6 · 2002 · cited in 1 Texas opinions naming this issue, 2004–2004
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 (34)

CaseCitedYears
Jackson v. State green
texcrimapp · 1994
2 sentences

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.

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.

41995–2021
Moon, Cameron red
texcrimapp · 2014
2 sentences

2018Id. at 49 .

2017Id. at 49 .

32017–2018
National Medical Enterprises, Inc. v. Godbey green
tex · 1996
2 sentences

2003Godbey , 924 S.W.2d at 132 .

2003Godbey, 924 S.W.2d at 132 .

22003–2003
Port Arthur Housing Co. v. City of Port Arthur green
texapp · 1944
2 sentences

1986The 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 .

21986–1986
Albrecht v. State green
texcrimapp · 1972
2 sentences

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 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

21975–1979
Bentinck v. Franklie green
tex · 1873
2 sentences

1962Bentinck v. Franklin, 38 Tex. 458 ; Stewart v. [Houston & T.

1962Bentinck v. Franklin, 38 Tex. 458 ; Stewart v. [Houston & T.

21922–1962
Southern Pacific Company v. Haas neutral
tex · 1892
2 sentences

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

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

21937–1938
Short v. Wade neutral
tex · 1860
2 sentences

1883Wade, 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.

21883–1883
Norton v. State green
texapp · 1988
1 sentence

2022The 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 .

12022–2022
Busby v. State green
texcrimapp · 1999
1 sentence

2019Thompson, 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.

12019–2019
Menefield v. State green
texcrimapp · 2012
1 sentence

2018Because 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.

12018–2018
Roberts v. United States Jaycees green
scotus · 1984
2 sentences

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").

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").

12018–2018
Bumpass v. Johnson green
texcommnapp · 1927
1 sentence

2015Strong 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).

12015–2015
Kaigler v. General Electric Mortgage Insurance Corp. green
texapp · 1998
12015–2015
Reyna v. State green
texcrimapp · 2005
12015–2015
In the Interest of K.M.S. green
tex · 2002
1 sentence

2015See Bekendam, 441 S.W.3d at 300 ; Reyna, 168 S.W.3d at 177-78 ; Martinez, 91 S.W.3d at 336-37 .

12015–2015
Uniroyal Goodrich Tire Co. v. Martinez green
tex · 1998
1 sentence

2015Hussami 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.

12015–2015
Stults v. State green
texapp · 2000
12013–2013
Hidalgo v. State green
texcrimapp · 1999
12013–2013
Zarate v. Cortinas green
texapp · 1977
12013–2013
Clemens v. McNamee green
txsd · 2009
12013–2013
Union City Body Co., Inc. v. Ramirez green
texapp · 1995
12012–2012
Hernandez v. New York green
scotus · 1991
11998–1998
Johnson v. Kinney green
texapp · 1995
11996–1996
Neal v. Neal green
texapp · 1980
11985–1985
Heath v. Boyd green
tex · 1943
11985–1985
Ex Parte Morgan green
texcrimapp · 1953
11982–1982
Lancaster Independent School District v. Pinson green
texapp · 1974
11976–1976
Evans v. Evans green
texapp · 1945
11972–1972
Biard v. Tyler Building & Loan Ass'n neutral
texapp · 1912
11972–1972
Davenport v. Lackie green
tex · 1852
11972–1972
Ellis v. Emil Blum Co. green
texapp · 1922
11972–1972
St. Paul's Sanitarium v. Freeman green
· 1909
11965–1965
Duvall v. Clark green
texapp · 1941
11965–1965

Statutes the citing opinions construe

TX § Tex. Fam. Code § 54.02 (6) TX § Tex. Penal Code § 19.03 (4) TX § Tex. Penal Code § 22.02 (4)

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

CA 213 (1865–2026) TX 118 (1878–2025) IL 100 (1892–2026) NY 97 (1849–2026) FL 59 (1878–2024) NJ 59 (1906–2024) IN 53 (1875–2019) WA 52 (1895–2023) OR 51 (1884–2026) PA 50 (1867–2025) AL 48 (1857–2025) CT 47 (1912–2026) LA 47 (1921–2024) GA 47 (1902–2026) MD 46 (1897–2025) MI 44 (1897–2026) MO 44 (1891–2024) MA 43 (1875–2025) VA 34 (1901–2025) TN 33 (1872–2025) IA 32 (1894–2020) WI 32 (1878–2020) KS 29 (1873–2004) NE 29 (1889–2020) MN 27 (1868–2026) OH 26 (1903–2025) AZ 21 (1922–2020) KY 21 (1889–2010) OK 21 (1893–2015) MS 21 (1935–2018) NM 19 (1930–2022) CO 17 (1898–2016) MT 17 (1922–2025) ID 15 (1928–1989) WV 15 (1913–2013) AR 15 (1892–1994) NC 13 (1903–2008) UT 13 (1907–2018) WY 13 (1916–2019) RI 12 (1894–2009) DE 11 (1942–2024) VT 11 (1919–2024) ME 11 (1822–2010) ND 11 (1903–2023) SD 9 (1895–1977) DC 8 (1978–2025) SC 8 (1884–2025) AK 7 (1980–2011) NH 6 (1871–2007) NV 5 (1872–1979) HI 3 (1910–1979)

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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