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

17 Texas opinions name it 2 courts 1960–2025 3 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 (10)

CaseFollowedCited
Wilson v. Dunngreen
tex · 1991 · cited in 9 Texas opinions naming this issue, 2004–2025
2 sentences

2025“For well over a century the rule has been firmly established in this state that a default judgment cannot withstand direct attack by a defendant who complains that he was not served in strict compliance with applicable requirements.” Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990).

2024According to Clayton, “the return of service showed only the citation was taped to the front gate and made no reference to the [petition in intervention].” “For well over a century the rule has been firmly established in this state that a default judgment cannot withstand direct attack by a defendant who complains that he was not served in strict compliance with applicable requirements.” Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990).

89
Uvalde Country Club v. Martin Linen Supply Co.green
tex · 1985 · cited in 4 Texas opinions naming this issue, 1991–2018
2 sentences

2018“If the record fails to show strict compliance with the rules relating to the issuance, service, and return of citation, error is apparent on the face of the record, and the attempted service of process is invalid.” Id. (citing Primate Constr., 884 S.W.2d at 152–53, and Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884, 885 (Tex. 1985) (per curiam)); see also Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990) (“For well over a century the rule has been firmly established in this state that a default judgment cannot withstand direct attack by a defendant who complains that he was not

2015"For well over a century the rule has been firmly established in this state that a default judgment cannot withstand direct attack by a defendant who complains that he was not served in strict compliance with applicable requirements." Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990); accord, e.g., Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884, 885 (Tex. 1985).

44
McKanna v. Edgargreen
tex · 1965 · cited in 2 Texas opinions naming this issue, 1991–2004
2 sentences

2004See, e.g., Uvalde Country Club v. Martin Linen Supply Co. , 690 S.W.2d 884, 886 (Tex.1985) (per curiam); McKanna v. Edgar , 388 S.W.2d 927, 929 (Tex.1965); Sloan v. Batte , 46 Tex. 215, 216 (1876)." Wilson , 800 S.W.2d at 836 .

1991See, e.g., Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884, 886 (Tex.1985) (per curiam); McKanna v. Edgar, 388 S.W.2d 927, 929 (Tex.1965); Sloan v. Batte, 46 Tex. 215, 216 (1876); see also R.

22
Sloan v. Battegreen
tex · 1876 · cited in 2 Texas opinions naming this issue, 1991–2004
2 sentences

2004See, e.g., Uvalde Country Club v. Martin Linen Supply Co. , 690 S.W.2d 884, 886 (Tex.1985) (per curiam); McKanna v. Edgar , 388 S.W.2d 927, 929 (Tex.1965); Sloan v. Batte , 46 Tex. 215, 216 (1876)." Wilson , 800 S.W.2d at 836 .

1991See, e.g., Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884, 886 (Tex.1985) (per curiam); McKanna v. Edgar, 388 S.W.2d 927, 929 (Tex.1965); Sloan v. Batte, 46 Tex. 215, 216 (1876); see also R.

22
Primate Construction, Inc. v. Silvergreen
tex · 1994 · cited in 2 Texas opinions naming this issue, 2018–2018
2 sentences

2018“If the record fails to show strict compliance with the rules relating to the issuance, service, and return of citation, error is apparent on the face of the record, and the attempted service of process is invalid.” Id. (citing Primate Constr., 884 S.W.2d at 152–53, and Uvalde Country Club v. Martin Linen Supply Co., 690 S.W.2d 884, 885 (Tex. 1985) (per curiam)); see also Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990) (“For well over a century the rule has been firmly established in this state that a default judgment cannot withstand direct attack by a defendant who complains that he was not

2018The Texas Supreme Court has “required that strict compliance with the rules for service of citation affirmatively appear on the record in order for a default judgment to withstand direct attack.” Primate Constr., Inc. v. Silver, 884 S.W.2d 151, 152 (Tex. 1994); see also Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990) (“For well over a century the rule has been firmly established in this state that a 1 Section 17.044(a)(2) provides: “The secretary of state is an agent for service of process or complaint on a nonresident who . . . has one or more resident agents for service of process, but two u

12
Owens-Corning Fiberglas Corp. v. Malonegreen
tex · 1998 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023See Malone, 972 S.W.2d at 43 .

11
BLS Development, LLC v. Manuel Lopezgreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018The Texas Supreme Court has “required that strict compliance with the rules for service of citation affirmatively appear on the record in order for a default judgment to withstand direct attack.” Primate Constr., Inc. v. Silver, 884 S.W.2d 151, 152 (Tex. 1994); see also Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex. 1990) (“For well over a century the rule has been firmly established in this state that a 1 Section 17.044(a)(2) provides: “The secretary of state is an agent for service of process or complaint on a nonresident who . . . has one or more resident agents for service of process, but two u

11
City of Garland v. Dallas Morning Newsgreen
tex · 2000 · cited in 1 Texas opinions naming this issue, 2013–2013
1 sentence

2013See City of Garland, 22 S.W.3d at 356 .

11
Insurance Co. of the State of Pennsylvania v. Lejeunegreen
tex · 2009 · cited in 1 Texas opinions naming this issue, 2011–2011
1 sentence

2011Co. of State of Pa. v. Lejeune , 297 S.W.3d 254, 255 (Tex. 2009) (noting that failure to strictly comply with rules for service of process constitutes error on face of record).

11
Felderhoff v. Felderhoffgreen
tex · 1971 · cited in 1 Texas opinions naming this issue, 1997–1997
2 sentences

1997Felderhoff v. Felderhoff, 473 S.W.2d 928, 930 (Tex.1971).

1997Felderhoff v. Felderhoff, 473 S.W.2d 928, 930 (Tex.1971).

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 (7)

CaseCitedYears
Bank of New York v. Chesapeake 34771 Land Trust green
texapp · 2015
1 sentence

2018"If the record fails to show strict compliance with the rules relating to the issuance, service, and return of citation, error is apparent on the face of the record, and the attempted service of process is invalid." Bank of N.Y. , 456 S.W.3d at 631 ; see also Wilson v. Dunn , 800 S.W.2d 833 , 836 (Tex. 1990) ("For well over a century the rule has been firmly established in this state that a default judgment cannot withstand direct attack by a defendant who complains that he was not served in strict compliance with applicable requirements.").

12018–2018
Methodist Hospitals of Dallas v. Mid-Century Insurance Co. of Texas green
texapp · 2008
1 sentence

2015Co. of Texas, 259 S.W.3d 358 (2008) statutory notice requirements, Methodist only complied with motions, the trial court granted Mid–Century's motion for two.

12015–2015
Railroad Commission v. Williams green
tex · 1962
2 sentences

1970Our conception of appellant’s position here is that the initial subdivision of the 17.8 acre tract is in derogation of Rule 37; however, appellant further contends that the Century rule, if applicable here, has been modified and subjected to the exception announced by the Supreme Court in Railroad Commission v. Williams, 163 Tex. 370 , 356 S.W.2d 131 (1961).

1970Our conception of appellant’s position here is that the initial subdivision of the 17.8 acre tract is in derogation of Rule 37; however, appellant further contends that the Century rule, if applicable here, has been modified and subjected to the exception announced by the Supreme Court in Railroad Commission v. Williams, 163 Tex. 370 , 356 S.W.2d 131 (1961).

11970–1970
Pickens v. Ryan Consol. Petroleum Corp. neutral
texapp · 1949
2 sentences

1961Petroleum Corporation, Tex.Civ.App., 219 S.W.2d 150 , writ ref., N.R.E., where we held, in reviewing an order of the Commission that a reconstructed tract, under the Century doctrine, 2 was entitled to a *393 well, leaving the rights of the owners to bq settled in a judicial proceeding. .This was subsequently done in a suit between the parties. 155 Tex. 221 , 285 S.W.2d 201 . • We believe that the answer to Coloma is found in the decisions discussing and deciding whether or not there has been an unlawful subdivision of a tract of land in order to avoid the spacing rules of the Commission.

1961Petroleum Corporation, Tex.Civ.App., 219 S.W.2d 150 , writ ref., N.R.E., where we held, in reviewing an order of the Commission that a reconstructed tract, under the Century doctrine, 2 was entitled to a *393 well, leaving the rights of the owners to bq settled in a judicial proceeding. .This was subsequently done in a suit between the parties. 155 Tex. 221 , 285 S.W.2d 201 . • We believe that the answer to Coloma is found in the decisions discussing and deciding whether or not there has been an unlawful subdivision of a tract of land in order to avoid the spacing rules of the Commission.

11961–1961
Ryan Consolidated Petroleum Corp. v. Pickens green
tex · 1955
2 sentences

1961Petroleum Corporation, Tex.Civ.App., 219 S.W.2d 150 , writ ref., N.R.E., where we held, in reviewing an order of the Commission that a reconstructed tract, under the Century doctrine, 2 was entitled to a *393 well, leaving the rights of the owners to bq settled in a judicial proceeding. .This was subsequently done in a suit between the parties. 155 Tex. 221 , 285 S.W.2d 201 . • We believe that the answer to Coloma is found in the decisions discussing and deciding whether or not there has been an unlawful subdivision of a tract of land in order to avoid the spacing rules of the Commission.

1961Petroleum Corporation, Tex.Civ.App., 219 S.W.2d 150 , writ ref., N.R.E., where we held, in reviewing an order of the Commission that a reconstructed tract, under the Century doctrine, 2 was entitled to a *393 well, leaving the rights of the owners to bq settled in a judicial proceeding. .This was subsequently done in a suit between the parties. 155 Tex. 221 , 285 S.W.2d 201 . • We believe that the answer to Coloma is found in the decisions discussing and deciding whether or not there has been an unlawful subdivision of a tract of land in order to avoid the spacing rules of the Commission.

11961–1961
Railroad Commission v. Humble Oil & Refining Co. green
tex · 1952
2 sentences

1961In Railroad Commission of Texas v. Humble Oil & Refining Co., 151 Tex. 51 , 245 S.W.2d 488, 489 , the Court stated: “ * * * after the promulgation of the Railroad Commission’s, spacing rule, owners of a single tract cannot, by their voluntary act, subdivide the tract, through leases or otherwise, and create for themselves, or those claiming under them, the right to additional drilling permits on small strips of land, under exceptions to a spacing rule relating to the protection of vested rights, because to permit them to do so would set at naught Rule 37 and the Conservation laws of Texas. * *

1961In Railroad Commission of Texas v. Humble Oil & Refining Co., 151 Tex. 51 , 245 S.W.2d 488, 489 , the Court stated: “ * * * after the promulgation of the Railroad Commission’s, spacing rule, owners of a single tract cannot, by their voluntary act, subdivide the tract, through leases or otherwise, and create for themselves, or those claiming under them, the right to additional drilling permits on small strips of land, under exceptions to a spacing rule relating to the protection of vested rights, because to permit them to do so would set at naught Rule 37 and the Conservation laws of Texas. * *

11961–1961
Railroad Commission v. Magnolia Petroleum Co. green
tex · 1937
2 sentences

1960The Century doctrine, referred to by appellee, was first pronounced in Railroad Commission of Texas v. Magnolia Petroleum Co., 130 Tex. 484 , 109 S.W.2d 967 .

1960The Century doctrine, referred to by appellee, was first pronounced in Railroad Commission of Texas v. Magnolia Petroleum Co., 130 Tex. 484 , 109 S.W.2d 967 .

11960–1960

Where else courts name it

TX 17 (1960–2025) CA 12 (1974–2023) GA 6 (1942–2025) NY 5 (2016–2024) CT 3 (1993–2000) MI 3 (2017–2017) PA 2 (1952–1984) OK 2 (2017–2017) IL 2 (2019–2021) MD 2 (1952–1958) NM 2 (1992–1992)

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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