collateral attack doctrine (Texas) · Go Syfert
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collateral attack doctrine in Texas

17 Texas opinions name it 4 courts 1926–2024 2 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 (5)

CaseFollowedCited
In the Interest of E.R.green
tex · 2012 · cited in 2 Texas opinions naming this issue, 2023–2024
2 sentences

2024However, I write separately because, in the collateral attack analysis, my opinion would begin where the majority opinion could have ended—in concluding Bell failed to exercise reasonable diligence so as to justify substituted service.1 See In re E.R., 385 S.W.3d 552, 564 (Tex. 2012) (“[i]f personal service can be effected by the exercise of reasonable diligence, substitute service is not to be resorted to” (quoting Sgitcovich v. Sgitcovich, 241 S.W.2d 142, 147 (Tex. 1951))).

2023However, I write separately because, in the collateral attack analysis, my opinion would begin where the majority opinion could have ended—in concluding Bell failed to exercise reasonable diligence so as to justify substituted service. 1 That is, even assuming without deciding that: (1) Bell exercised reasonable diligence in attempting to personally serve JD Auto’s authorized agent so as to justify substituted service; and (2) Bell posted notice at the courthouse in compliance with the trial court’s substituted service order, JD Auto’s collateral 1 See In re E.R., 385 S.W.3d 552, 564 (Tex. 201

22
Sgitcovich v. Sgitcovichgreen
tex · 1951 · cited in 2 Texas opinions naming this issue, 2023–2024
2 sentences

2024However, I write separately because, in the collateral attack analysis, my opinion would begin where the majority opinion could have ended—in concluding Bell failed to exercise reasonable diligence so as to justify substituted service.1 See In re E.R., 385 S.W.3d 552, 564 (Tex. 2012) (“[i]f personal service can be effected by the exercise of reasonable diligence, substitute service is not to be resorted to” (quoting Sgitcovich v. Sgitcovich, 241 S.W.2d 142, 147 (Tex. 1951))).

2023However, I write separately because, in the collateral attack analysis, my opinion would begin where the majority opinion could have ended—in concluding Bell failed to exercise reasonable diligence so as to justify substituted service. 1 That is, even assuming without deciding that: (1) Bell exercised reasonable diligence in attempting to personally serve JD Auto’s authorized agent so as to justify substituted service; and (2) Bell posted notice at the courthouse in compliance with the trial court’s substituted service order, JD Auto’s collateral 1 See In re E.R., 385 S.W.3d 552, 564 (Tex. 201

22
Narvaez v. Maldonadogreen
texapp · 2004 · cited in 2 Texas opinions naming this issue, 2009–2009
2 sentences

2009Narvaez v. Maldonado, 127 S.W.3d 313, 317 (Tex. App.—Austin 2004, no pet.).3 Because both Park and Western Union characterize Western Union’s jurisdictional challenge as a collateral attack on the underlying default judgment, we will proceed under a collateral-attack analysis.

2009Narvaez v. Maldonado , 127 S.W.3d 313, 317 (Tex. App.--Austin 2004, no pet.). (3) Because both Park and Western Union characterize Western Union's jurisdictional challenge as a collateral attack on the underlying default judgment, we will proceed under a collateral-attack analysis.

22
Cook v. Camerongreen
tex · 1987 · cited in 1 Texas opinions naming this issue, 2003–2003
1 sentence

2003See Cook v. Cameron, 733 S.W.2d 137, 140 (Tex.1987).

11
White v. Whitegreen
tex · 1944 · cited in 1 Texas opinions naming this issue, 1992–1992
1 sentence

1992See also White v. White , 179 S.W.2d 503, 506 (Tex. 1944) (holding as impermissible a collateral attack to challenge the jurisdiction of a court issuing a binding judgment which is regular on its face and on the record).

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 (17)

CaseCitedYears
In Re AGG green
texapp · 2008
2 sentences

2009In re A.G.G., 267 S.W.3d at 169 .

2009In re A.G.G., 267 S.W.3d at 169 .

42009–2009
Creedmoor-Maha Water Supply Corp. v. Texas Commission on Environmental Quality green
texapp · 2010
1 sentence

2016Doe cannot collaterally attack the hearing officer’s determination through a declaratory action, because UDJA claims generally cannot provide “relief against agency orders from which the legislature has not granted a right of judicial review and thereby waived sovereign immunity.” Creedmoor-Maha, 307 S.W.3d at 515 .

12016–2016
cluster 610597 green
ca5 · 1993
1 sentence

2015United Sta s v. Ga rc ia -Jasso, 4/ 2 F. 3d 239, 243 (5th Cir. 2006) (quoting United States v. Vaquero, 997 F.2d 78 , 79 -(5th Cir. 1993).

12015–2015
Holder v. Scott green
texapp · 1965
1 sentence

2004Appellants cite three cases as authority for their unique application of the collateral attack rule: Starnes v. Holloway, 779 S.W.2d 86 (Tex.App.-Dallas 1989, writ denied); Dews v. Floyd, 418 S.W.2d 800 (Tex.Civ.App.-Tyler 1967, no writ); and Holder v. Scott, 396 S.W.2d 906 (Tex.Civ.App.-Texarkana 1965, writ refd n.r.e.).

12004–2004
Starnes v. Holloway green
texapp · 1989
1 sentence

2004Appellants cite three cases as authority for their unique application of the collateral attack rule: Starnes v. Holloway, 779 S.W.2d 86 (Tex.App.-Dallas 1989, writ denied); Dews v. Floyd, 418 S.W.2d 800 (Tex.Civ.App.-Tyler 1967, no writ); and Holder v. Scott, 396 S.W.2d 906 (Tex.Civ.App.-Texarkana 1965, writ refd n.r.e.).

12004–2004
Wood v. Downing neutral
ark · 1967
1 sentence

2004Appellants cite three cases as authority for their unique application of the collateral attack rule: Starnes v. Holloway, 779 S.W.2d 86 (Tex.App.-Dallas 1989, writ denied); Dews v. Floyd, 418 S.W.2d 800 (Tex.Civ.App.-Tyler 1967, no writ); and Holder v. Scott, 396 S.W.2d 906 (Tex.Civ.App.-Texarkana 1965, writ refd n.r.e.).

12004–2004
Aguilar v. Texas red
scotus · 1964
2 sentences

1965We have now concluded that even though petitioner was in the appellate process at the time the Supreme Court handed down Aguilar v. State of Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 , he may not avail himself in this collateral attack of the rule therein announced because of his failure to object to the introduction of the fruits of the search at the time of trial.

1965We have now concluded that even though petitioner was in the appellate process at the time the Supreme Court handed down Aguilar v. State of Texas, 378 U.S. 108 , 84 S.Ct. 1509 , 12 L.Ed.2d 723 , he may not avail himself in this collateral attack of the rule therein announced because of his failure to object to the introduction of the fruits of the search at the time of trial.

11965–1965
Tuck v. Patterson green
texapp · 1933
1 sentence

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
McCampbell v. Durst neutral
tex · 1889
2 sentences

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Fisher v. Wood neutral
tex · 1885
1 sentence

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Kreis v. Kreis neutral
texapp · 1933
1 sentence

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Miller v. Carlton green
texapp · 1893
2 sentences

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Nuckols v. Stanger neutral
texapp · 1913
1 sentence

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Johnston v. Stephens green
· 1932
2 sentences

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Storer v. Lane. neutral
texapp · 1892
2 sentences

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

1941This court concludes that the trial court erred in so determining that removal of such pre-existing judgment by direct attack thereon was an indispensable prerequisite to the maintenance of this action; hence, that plaintiffs'in error’s quoted first assignment should be sustained; in other words, our authorities hold that, in such an instance as this, where a purchaser at a judicial sale is alleged to have acquired the property in fraud both of the court through which the proceedings were had and of the plaintiff himself, that it passed by constructive trust for the benefit of the *922 defraud

11941–1941
Boggess v. Howard green
tex · 1874
1 sentence

1927Dec. 657 ; Boggess v. Howard, 40 Tex. 153 ), or invoke the doctrine of collateral attack (Freeman on Judgments [5th Ed.] p. 788).

11927–1927
Crawford v. McDonald green
tex · 1895
1 sentence

1926As said by the Supreme Court in Crawford v. McDonald, 88 Tex. 626 , 33 S. W. 325 : “It is well settled that, where a personal judgment has been rendered against a defendant by a domestic court of general jurisdiction, and under the “judgment” property has been seized and sold, he will not, in a contest over the title to the property, be allowed to show by evidence dehors the record that the judgment was rendered without any service * * * upon him.” This was said in a case of collateral attack, where the judgment recited legal service upon the defendant, and the rule is definitely settled in Te

11926–1926

Statutes the citing opinions construe

TX § Tex. Fam. Code § 102.003 (4) TX § Tex. Fam. Code § 105.001 (4) TX § Tex. Fam. Code § 109.002 (4) TX § Tex. Fam. Code § 153.002 (4) TX § Tex. Fam. Code § 153.131 (4) TX § Tex. Fam. Code § 153.193 (4) TX § Tex. Fam. Code § 156.002 (4) TX § Tex. Fam. Code § 102.004 (3)

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

MI 17 (1897–2020) IL 17 (1979–2025) TX 17 (1926–2024) PA 8 (1979–2024) HI 7 (2008–2025) OH 5 (2007–2018) WI 4 (2005–2023) NY 4 (1984–2022) CT 3 (2016–2022) WA 3 (1974–2001) OK 2 (1975–2000) KY 2 (1976–2010) FL 2 (1967–1993) IN 2 (1993–2018) AZ 2 (2006–2014) CA 2 (1960–2014) ND 2 (1992–2022) MD 2 (2011–2013)

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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