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21 Texas opinions name it 4 courts 1991–2026 5 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 |
|---|---|---|
Ramirez v. Stategreen2 sentences2026P. 33.1; Hicks v. State, 718 S.W.3d 554 , 562 (Tex. App.—Houston [14th Dist.] 2025, pet. ref’d) (“The trial court must make an adverse ruling; ‘that is, it must be clear from the record the trial judge in fact overruled the defendant’s objection or otherwise error is waived.’” (quoting Ramirez v. State, 815 S.W.2d 636, 643 (Tex. Crim. App. 1991)). 2026The adverse ruling “must be conclusory; that is, it must be clear from the record the trial judge in fact overruled the defendant’s objection or otherwise error is waived.” Ramirez v. State, 815 S.W.2d 636, 643 (Tex. Crim. App. 1991). | 12 | 17 |
Rey v. Stategreen2 sentences2023However, the ruling “need not be expressly stated” if the trial court’s “actions or other statements otherwise unquestionably indicate a ruling.” Rey v. State, 897 S.W.2d 333, 336 (Tex. Crim. App. 1995). 2019A trial court’s ruling on a matter need not be expressly stated if its actions or other statements “otherwise unquestionably indicate a ruling.” Montanez v. State, 195 S.W.3d 101, 104 (Tex. Crim. App. 2006) (quoting Rey v. State, 897 S.W.2d 333, 336 (Tex. Crim. App. 1995)); Ramirez v. State, 815 S.W.2d 12 636, 643 (Tex. Crim. App. 1991) (“[I]t must be clear from the record the trial judge in fact overruled the defendant’s objection or otherwise error is waived.”). | 2 | 2 |
Bailey v. Stategreen2 sentences2013App. 1991) (en banc) (citing Bailey v. State, 532 S.W.2d 316, 322 (Tex. Crim. 1991Bailey v. State, 532 S.W.2d 316, 322 (Tex.Cr.App.1975). | 2 | 2 |
Mercado v. Stategreen2 sentences2012App. P. 33.1(a)(1); Mercado v. State , 718 S.W.2d 291, 296 (Tex. Crim. 2012App. P. 33.1(a)(1); Mercado v. State, 718 S.W.2d 291, 296 (Tex. Crim. | 2 | 2 |
Lear v. Norfolk & Western Railway Co.green1 sentence2019A trial court’s ruling on a matter need not be expressly stated if its actions or other statements “otherwise unquestionably indicate a ruling.” Montanez v. State, 195 S.W.3d 101, 104 (Tex. Crim. App. 2006) (quoting Rey v. State, 897 S.W.2d 333, 336 (Tex. Crim. App. 1995)); Ramirez v. State, 815 S.W.2d 12 636, 643 (Tex. Crim. App. 1991) (“[I]t must be clear from the record the trial judge in fact overruled the defendant’s objection or otherwise error is waived.”). | 1 | 1 |
Montanez v. Stategreen1 sentence2019A trial court’s ruling on a matter need not be expressly stated if its actions or other statements “otherwise unquestionably indicate a ruling.” Montanez v. State, 195 S.W.3d 101, 104 (Tex. Crim. App. 2006) (quoting Rey v. State, 897 S.W.2d 333, 336 (Tex. Crim. App. 1995)); Ramirez v. State, 815 S.W.2d 12 636, 643 (Tex. Crim. App. 1991) (“[I]t must be clear from the record the trial judge in fact overruled the defendant’s objection or otherwise error is waived.”). | 1 | 1 |
Murillo v. Stategreen2 sentences2012In Murillo v. State, 839 S.W.2d 485, 493 (Tex. App.—El Paso 1992, no pet.), Murillo objected to certain testimony, and the trial court responded to the objection by saying, "You may proceed." The Murillo Court, relying on the law stated in Ramirez, held this response "did not constitute a conclusory or definite ruling adverse to the objection." Id. 2012In Murillo v. State, 839 S.W.2d 485, 493 (Tex. App.—El Paso 1992, no pet.), Murillo objected to certain testimony, and the trial court responded to the objection by saying, "You may proceed." The Murillo Court, relying on the law stated in Ramirez, held this response "did not constitute a conclusory or definite ruling adverse to the objection." Id. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
State v. Kelley
green
1 sentence2016An implied ruling by the trial court may be sufficient to preserve error “when the objection was brought to the trial court’s attention and the trial court’s subsequent action clearly addressed the complaint.” See State v. Kelley, 20 S.W.3d 147 , 153 n.3 (Tex. App.—Texarkana 2000, no pet.); see also TEX. | 1 | 2016–2016 |
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.