Carroll doctrine (Texas) · Go Syfert
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Carroll doctrine in Texas

17 Texas opinions name it 2 courts 1939–2021 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 (9)

CaseFollowedCited
Haley v. Stategreen
texcrimapp · 2005 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018To preserve error for appellate review, Rule 33.1 of the Texas Rules of Appellate Procedure “requires that the record demonstrate (1) the complaining party made a timely and specific request, objection, or motion; and (2) the trial judge either ruled on the request, objection, or motion, or he refused to rule and the complaining party objected to that refusal.” Haley v. State, 173 S.W.3d 510, 516 (Tex. Crim.

11
Stoddard v. Stategreen
texcrimapp · 1972 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015“While the nature and 50 normal use of an automobile will often be the key factor in providing the ‘exigent circumstances’ in situations where otherwise they would not exist, nevertheless the fact that the place to be searched is a car is but one factor, an important one, in making the determination as to the existence of the ‘exigent circumstances.’ It is not the only factor to be considered.” Stoddard v. State, 475 S.W.2d 744, 752 (Tex. Crim.

2015“While the nature and 50 normal use of an automobile will often be the key factor in providing the ‘exigent circumstances’ in situations where otherwise they would not exist, nevertheless the fact that the place to be searched is a car is but one factor, an important one, in making the determination as to the existence of the ‘exigent circumstances.’ It is not the only factor to be considered.” Stoddard v. State, 475 S.W.2d 744, 752 (Tex. Crim.

11
Cardwell v. Lewisgreen
scotus · 1974 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015Cardwell v. Lewis, 417 U.S. 583, 598 (1974) (Stewart, J., dissenting, joined by Douglas, Brennan, and Marshall, JJ.) (“Where there is no reasonable likelihood that the automobile would or could be moved, the Carroll doctrine is simply inapplicable.”).

2015Cardwell v. Lewis, 417 U.S. 583, 598 (1974) (Stewart, J., dissenting, joined by Douglas, Brennan, and Marshall, JJ.) (“Where there is no reasonable likelihood that the automobile would or could be moved, the Carroll doctrine is simply inapplicable.”).

11
Pena v. Stategreen
texapp · 2007 · cited in 1 Texas opinions naming this issue, 2008–2008
1 sentence

2008In Pena v. State, this Court held that, “under the Due Course of Law provision of article I, section 19 [of the Texas Constitution], the State has a duty to preserve material evidence which has apparent exculpatory value, encompassing both exculpatory evidence and evidence that is potentially useful to the defense.” 226 S.W.3d 634, 651 (Tex.App.-Waco 2007, pet. granted).

11
Texas Workers' Compensation Commission v. Garciagreen
tex · 1995 · cited in 1 Texas opinions naming this issue, 2007–2007
1 sentence

2007See Texas Workers’ Compensation Comm’n v. Garcia, 893 S.W.2d 504 , 517 n.15 (Tex. 1995). 3 In its summary-judgment motion, the Estate asserts that Carroll has “no evidence to establish any element of any of her claims.” It enumerates the claims and elements it is challenging, including Carroll’s claim to “a share of [Hempel’s] estate if: (x) the Court admits to probate the 1960 and 1969 joint and mutual will and codicil; and (y) the Court determines that a gift therein has lapsed and such gift would pass by intestacy.” 13 CONCLUSION We affirm the judgment of the district court. _______________

11
State v. Guzmangreen
texcrimapp · 1998 · cited in 1 Texas opinions naming this issue, 2000–2000
2 sentences

2000See State v. Guzman, 959 S.W.2d 631, 634 (Tex.Crim.App.1998).

2000See State v. Guzman, 959 S.W.2d 631, 634 (Tex.Crim.App.1998).

11
Morrison v. Changreen
tex · 1985 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995Morrison v. Chan , 699 S.W.2d 205, 206-07 (Tex. 1985); Voskamp v. Arnoldy , 749 S.W.2d 113, 127 (Tex. App.--Houston [1st Dist.] 1987, writ denied).

11
Voskamp v. Arnoldygreen
texapp · 1988 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995Morrison v. Chan , 699 S.W.2d 205, 206-07 (Tex. 1985); Voskamp v. Arnoldy , 749 S.W.2d 113, 127 (Tex. App.--Houston [1st Dist.] 1987, writ denied).

11
Kiser v. Lemco Industries, Inc.green
texapp · 1975 · cited in 1 Texas opinions naming this issue, 1980–1980
1 sentence

1980See Kiser v. Lemco Industries, Inc., 521 S.W.2d 142 (Tex.Civ.App. — Amarillo 1975, no writ); Houston Heating & Air Conditioning, Inc. v. Semands, 318 S.W.2d 777 (Tex.Civ.App.— Waco 1958, writ dism’d); Coffield v. Richter, 229 S.W.2d 97 (Tex.Civ.App. — Austin 1950, no writ).

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 (11)

CaseCitedYears
Hayes v. Carroll green
texapp · 2010
2 sentences

2011Hayes, 314 S.W.3d at 502 ; accord Davis v. Baker, No. 03-10-00324-CV, 2010 WL 5463864 , at *4, 2010 Tex.App.

2011Hayes, 314 S.W.3d at 502 ; accord Davis v. Baker, No. 03- 10-00324-CV, 2010 Tex. App. LEXIS 10317 , at *12 (Tex. App.—Austin, Dec. 22, 2010, no pet. h.); Daybreak Cmnty.

32011–2011
Carroll v. State green
texapp · 2008
2 sentences

2008In Carroll v. State, 266 S.W.3d 1 (Tex.App.-Waco 2008, no pet. h.), Carroll challenged the trial court’s refusal to submit a spoliation instruction to the jury “concerning the State’s failure to preserve video *634 tapes of Carroll’s stop and arrest.” Carroll, 266 S.W.3d at 3 .

2008In Carroll v. State, 266 S.W.3d 1 (Tex.App.-Waco 2008, no pet. h.), Carroll challenged the trial court’s refusal to submit a spoliation instruction to the jury “concerning the State’s failure to preserve video *634 tapes of Carroll’s stop and arrest.” Carroll, 266 S.W.3d at 3 .

22008–2008
Almeida-Sanchez v. United States green
scotus · 1973
2 sentences

1982“Automobile or no automobile, there must be probable cause for the search.” Almeida-Sanchez v. United States, 413 U.S. 266 , 93 S.Ct. 2535 , 37 L.Ed.2d 596 (1973).

1982“Automobile or no automobile, there must be probable cause for the search.” Almeida-Sanchez v. United States, 413 U.S. 266 , 93 S.Ct. 2535 , 37 L.Ed.2d 596 (1973).

21981–1982
Northwest Independent School District v. Carroll Independent School District green
texapp · 2014
1 sentence

2021Before Carroll filed its sixth amended petition adding the ultra vires claim, we had already concluded in Carro// IT that “the [DJA] applies when, as here, a school district seeks to resolve a controversy regarding a judgment or order issued by a commissioners court even though the words Judgment’ and ‘order’ are not contained within the specific enumerations listed in the Act.” 441 S.W.3d at 691 .

12021–2021
In Re KAF green
tex · 2005
1 sentence

2015No claim to original U.S. Government Works. 6 In re K.A.F., 160 S.W.3d 923 (2005) 74 USLW 3132 , 48 Tex. Sup. Ct. J. 565 IV [6] Finally, Carroll raises two constitutional issues should we hold, as we have, that her appeal was untimely.

12015–2015
In the Interest of K.A.F. neutral
tex · 2005
1 sentence

2015No claim to original U.S. Government Works. 6 In re K.A.F., 160 S.W.3d 923 (2005) 74 USLW 3132 , 48 Tex. Sup. Ct. J. 565 IV [6] Finally, Carroll raises two constitutional issues should we hold, as we have, that her appeal was untimely.

12015–2015
Gill v. State green
texcrimapp · 1981
2 sentences

1982Gill v. State, 625 S.W.2d 307 (Tex.Cr.App.1981).

1982Gill v. State, 625 S.W.2d 307 (Tex.Cr.App.1981).

11982–1982
Carroll v. United States green
scotus · 1925
2 sentences

1981Carroll v. United States, 267 U.S. 132 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925). " Carroll has been followed in a line of subsequent cases, but the Carroll doctrine does not declare a field day for the police in searching automobiles.

1981Carroll v. United States, 267 U.S. 132 , 45 S.Ct. 280 , 69 L.Ed. 543 (1925). " Carroll has been followed in a line of subsequent cases, but the Carroll doctrine does not declare a field day for the police in searching automobiles.

11981–1981
Coffield v. Richter neutral
texapp · 1950
1 sentence

1980See Kiser v. Lemco Industries, Inc., 521 S.W.2d 142 (Tex.Civ.App. — Amarillo 1975, no writ); Houston Heating & Air Conditioning, Inc. v. Semands, 318 S.W.2d 777 (Tex.Civ.App.— Waco 1958, writ dism’d); Coffield v. Richter, 229 S.W.2d 97 (Tex.Civ.App. — Austin 1950, no writ).

11980–1980
Houston Heating & Air Conditioning, Inc. v. Semands neutral
texapp · 1958
1 sentence

1980See Kiser v. Lemco Industries, Inc., 521 S.W.2d 142 (Tex.Civ.App. — Amarillo 1975, no writ); Houston Heating & Air Conditioning, Inc. v. Semands, 318 S.W.2d 777 (Tex.Civ.App.— Waco 1958, writ dism’d); Coffield v. Richter, 229 S.W.2d 97 (Tex.Civ.App. — Austin 1950, no writ).

11980–1980
Edmondson v. Carroll green
texapp · 1933
1 sentence

1939Edmondson again appealed to this court, and by an opinion reported in Edmondson v. Carroll, 65 S.W.2d 1107, 1110 , writ dismissed, the judgment of the trial court was affirmed in part and reversed and remanded in part, in this language: “The cause is remanded to the trial court for a trial of the cross-action of appellant [Edmondson].

11939–1939

Where else courts name it

MD 49 (1967–2026) FL 17 (1969–2022) TX 17 (1939–2021) AL 16 (1972–2018) CA 12 (1973–2013) GA 8 (1976–2007) IA 7 (1971–2015) LA 7 (1962–1987) VA 7 (1997–2026) WV 5 (1980–1982) MA 4 (1975–2001) MI 4 (1974–2022) IL 4 (1981–2022) MT 4 (1992–2025) OH 4 (2004–2024) MS 4 (1972–2025) PA 4 (2004–2024) NJ 4 (1979–1989) MN 3 (1974–2014) WI 3 (2001–2023) HI 3 (1970–2020) IN 3 (1995–2004) MO 3 (1991–2000) KY 2 (1971–2001) SC 2 (2004–2007) NE 2 (1991–2014) AZ 2 (1977–1984) NY 2 (1979–2024) KS 2 (2018–2020) DC 2 (1974–1992) ID 2 (1991–2001) NC 2 (2021–2021)

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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