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16 Texas opinions name it 2 courts 2007–2025 6 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 |
|---|---|---|
Atmos Energy Corp. v. Abbottgreen2 sentences2020See Atmos Energy Corp. v. Abbott, 127 S.W.3d 852, 857 (Tex. App.—Austin 2004, no pet.). 2015See Atmos Energy Corp., 127 S.W.3d at 858 . | 8 | 8 |
TransUnion LLC v. Ramirezgreen2 sentences2025See Texas Ass’n of Business v. Texas Air Control Board, 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient”); Grassroots Leadership, Inc. v. Texas Dep’t of Family & Protective Services, 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete- injury requirement for injunctive relief” (citing TransUnion LLC v. Ramirez, 594 U.S. 413 , 435-36 (2021); Clapper v. Amnesty Int’l USA, 568 U.S. 398 , 414 n.5 (2013)). 2025Independent from taxpayer standing, I believe Appellants have established standing to seek injunctive relief. “[A] substantial risk may satisfy the concrete-injury requirement for injunctive relief, if that risk is based on a reasonable inference from specifically alleged, current facts.” Grassroots Leadership, Inc. v. Tex. Dep’t of Fam. & Protective Servs., 646 S.W.3d 815 , -8- 820 (Tex. 2022) (citing TransUnion LLC v. Ramirez, 594 U.S. 413, 435 (2021)); TransUnion LLC, 594 U.S. at 435 (“[A] person exposed to a risk of future harm may pursue forward-looking, injunctive relief to prevent the h | 2 | 3 |
Texas Ass'n of Business v. Texas Air Control Boardgreen2 sentences2025See Texas Ass’n of Business v. Texas Air Control Board, 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient”); Grassroots Leadership, Inc. v. Texas Dep’t of Family & Protective Services, 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete- injury requirement for injunctive relief” (citing TransUnion LLC v. Ramirez, 594 U.S. 413 , 435-36 (2021); Clapper v. Amnesty Int’l USA, 568 U.S. 398 , 414 n.5 (2013)). 2025Grassroots Leadership, Inc. v. Tex. Dep’t of Fam. & Protective Servs., 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete-injury requirement for injunctive relief . . . .”); Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient under Hunt[ v. Washington State Apple Advertising Comm’n, 432 U.S. 333, 343 (1977)],” for associational standing). | 2 | 2 |
Grassroots Leadership, Inc. v. Texas Department of Family and Protective Servicesgreen2 sentences2025See Texas Ass’n of Business v. Texas Air Control Board, 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient”); Grassroots Leadership, Inc. v. Texas Dep’t of Family & Protective Services, 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete- injury requirement for injunctive relief” (citing TransUnion LLC v. Ramirez, 594 U.S. 413 , 435-36 (2021); Clapper v. Amnesty Int’l USA, 568 U.S. 398 , 414 n.5 (2013)). 2025Grassroots Leadership, Inc. v. Tex. Dep’t of Fam. & Protective Servs., 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete-injury requirement for injunctive relief . . . .”); Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient under Hunt[ v. Washington State Apple Advertising Comm’n, 432 U.S. 333, 343 (1977)],” for associational standing). | 1 | 3 |
Kerry Heckman, on Behalf of Themselves and All Other Persons Similarly Situated v. Williamson Countygreen2 sentences2025See also Heckman v. Williamson Cnty., 369 S.W.3d 137 , 152 n.60 (Tex. 2012) (“Because standing is a constitutional prerequisite to maintaining a suit under both federal and Texas law, we look to the more extensive jurisprudential experience of the federal courts on this subject for any guidance it may yield.”). 2021This portion of the standing doctrine requires the plaintiff to “plead facts demonstrating that he, himself (rather than a third party or the public at large), suffered the injury.” Meyers, 548 S.W.3d at 485 (quoting Heckman, 369 S.W.3d at 155 ). | 1 | 2 |
Hunt v. Washington State Apple Advertising Commissiongreen1 sentence2025Grassroots Leadership, Inc. v. Tex. Dep’t of Fam. & Protective Servs., 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete-injury requirement for injunctive relief . . . .”); Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient under Hunt[ v. Washington State Apple Advertising Comm’n, 432 U.S. 333, 343 (1977)],” for associational standing). | 1 | 1 |
DaimlerChrysler Corp. v. Inmangreen1 sentence2018Appellees’ alleged injury of lengthier detention caused by the FRC Rule is also too speculative to meet the concrete-injury requirement of the standing analysis.8 See DaimlerChrysler Corp., 252 S.W.3d at 307 (“[I]f injury is only hypothetical, there is no real controversy.”). | 1 | 1 |
Brooks v. Northglen Ass'ngreen2 sentences2015II, § 1 (separation of powers); Brooks, 141 S.W.3d at 164 (explaining that separation of powers provision bars issuance of advisory opinions)). “[T]here must be a concrete injury for the claim to be ripe.” Id. 2015II, § 1 (separation of powers); Brooks, 141 S.W.3d at 164 (explaining that separation of powers provision bars issuance of advisory opinions)). “[T]here must be a concrete injury for the claim to be ripe.” Id. | 1 | 1 |
City of Austin v. Whittingtongreen1 sentence2013City of Austin v. Whittington, 385 S.W.3d 28, 33 (Tex. App.-Austin 2007, no pet.); see also Patterson v. Planned Parenthood of Houston & Se. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Clapper v. Amnesty International USA
green
2 sentences2025See Texas Ass’n of Business v. Texas Air Control Board, 852 S.W.2d 440, 447 (Tex. 1993) (“A substantial risk of injury is sufficient”); Grassroots Leadership, Inc. v. Texas Dep’t of Family & Protective Services, 646 S.W.3d 815 , 820 (Tex. 2022) (“[A] substantial risk may satisfy the concrete- injury requirement for injunctive relief” (citing TransUnion LLC v. Ramirez, 594 U.S. 413 , 435-36 (2021); Clapper v. Amnesty Int’l USA, 568 U.S. 398 , 414 n.5 (2013)). 2022TransUnion LLC v. Ramirez, 141 S. Ct. 2190, 2210 (2021); Clapper v. Amnesty Int’l USA, 568 U.S. 398 , 414 n.5 (2013) (noting that standing can derive from “‘substantial risk’ that the harm will occur,” but that plaintiffs must plead and prove “concrete facts showing that the defendant’s actual action has caused the substantial risk of harm”). | 2 | 2022–2025 |
Andrade v. NAACP of Austin
green
1 sentence2022Andrade v. NAACP of Austin, 345 S.W.3d 1 , 17–18 (Tex. 2011). | 1 | 2022–2022 |
Meyers v. JDC/Firethorne, Ltd.
green
1 sentence2021This portion of the standing doctrine requires the plaintiff to “plead facts demonstrating that he, himself (rather than a third party or the public at large), suffered the injury.” Meyers, 548 S.W.3d at 485 (quoting Heckman, 369 S.W.3d at 155 ). | 1 | 2021–2021 |
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.
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.