four factor test (Texas) · Go Syfert
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four factor test in Texas

16 Texas opinions name it 3 courts 1989–2025 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 (8)

CaseFollowedCited
Gigliobianco v. Stategreen
texcrimapp · 2006 · cited in 7 Texas opinions naming this issue, 2015–2017
2 sentences

2017Gigliobianco v. State, 210 S.W.3d 637, 641-42 (Tex.Crim.App. 2006) (noting these factors as a refinement to a four factor test appearing in prior cases).

2017Gigliobianco v. State, 210 S.W.3d 637, 641-42 (Tex.Crim.App. 2006) (noting these factors as a refinement to a four factor test appearing in prior cases).

77
In Re Nexion Health at Humble, Inc.green
tex · 2005 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010Id. at 780 ; In re Nexion Health at Humble, Inc., 173 S.W.3d 67, 69 (Tex. 2005)(per curiam).

2010Id. at 780 ; In re Nexion Health at Humble, Inc., 173 S.W.3d 67, 69 (Tex. 2005)(per curiam).

22
Julie Hersh v. John Tatum and Mary Ann Tatumgreen
tex · 2017 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025McComb also relies on American Heritage Capital, LP v. Gonzalez for the proposition that four factors are relevant to the assessment of TCPA sanctions: (1) the plaintiff’s annual net profits; (2) the amount of attorney’s fees incurred; (3) the plaintiff’s history of filing similar suits; and (4) any aggravating misconduct. 436 S.W.3d 865, 881 (‘Tex. App.––Dallas 2014, no pet.) (noting facts relevant to these four topics without articulating a four- factor test), disapproved of on other grounds by Hersh v. Tatum, 526 S.W.3d 462, 467 (Tex. 2017); see ADB Int., LLC v. Wallace, 606 S.W.3d 413 , 44

11
American Heritage Capital, LP v. Dinah Gonzalez and Alan Gonzalezgreen
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025McComb also relies on American Heritage Capital, LP v. Gonzalez for the proposition that four factors are relevant to the assessment of TCPA sanctions: (1) the plaintiff’s annual net profits; (2) the amount of attorney’s fees incurred; (3) the plaintiff’s history of filing similar suits; and (4) any aggravating misconduct. 436 S.W.3d 865, 881 (‘Tex. App.––Dallas 2014, no pet.) (noting facts relevant to these four topics without articulating a four- factor test), disapproved of on other grounds by Hersh v. Tatum, 526 S.W.3d 462, 467 (Tex. 2017); see ADB Int., LLC v. Wallace, 606 S.W.3d 413 , 44

11
Scott v. Stategreen
texcrimapp · 1979 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021Huskey and Landrian both relied on Scott v. State, in which the Court of Criminal Appeals considered the four factors in holding that the trial court erred in refusing to reopen the evidence after both sides closed to allow the defendant to present an alibi witness. 597 S.W.2d 755, 758 (Tex. Crim.

11
Torres v. Stategreen
texcrimapp · 2005 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021We granted review to determine whether the court of appeals misapplied the four- factor test from Brown and whether the court of appeals= finding of probable cause was based on opinions rather than facts in conflict with Torres v. State, 182 S.W.3d 899, 902 (Tex. Crim.

11
Fleming v. Jefferson County School District R-1green
ca10 · 2002 · cited in 1 Texas opinions naming this issue, 2017–2017
1 sentence

2017Id. at 923.

11
Ex Parte De Los Reyesgreen
texapp · 2011 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015The COA for the Eight District reasoned that “[w]hile the State points us to a four-factor approach to prejudice that our sister circuit in Houston has taken that assesses a defendant’s probability of success at trial,…, we have previously rejected a solely merits-based prejudice analysis, recognizing that ‘[d]eprivation of a trial’ stemming from a Padilla violation ‘is a structural defect, which amounts to a serious denial of the entire judicial proceeding itself, and it demands a presumption of prejudice.’ Ex parte De Los Reyes, 350 S.W.3d 723, 730 (Tex.App.--El Paso 2011, pet. granted), rev

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 (4)

CaseCitedYears
In Re D. Wilson Const. Co. green
tex · 2006
2 sentences

2010Id. at 780 ; In re Nexion Health at Humble, Inc., 173 S.W.3d 67, 69 (Tex. 2005)(per curiam).

2010Id. at 780 ; In re Nexion Health at Humble, Inc., 173 S.W.3d 67, 69 (Tex. 2005)(per curiam).

22010–2010
Bertell Ollman v. Rowland Evans, Robert Novak green
cadc · 1984
2 sentences

1989Id. at 979 ; Kerr, 706 S.W.2d at 798 .

1989Oilman, 750 F.2d at 979 ; Kerr, 706 S.W.2d at 798 .

21989–1989
El Paso Times, Inc. v. Kerr green
texapp · 1986
2 sentences

1989Id. at 979 ; Kerr, 706 S.W.2d at 798 .

1989Oilman, 750 F.2d at 979 ; Kerr, 706 S.W.2d at 798 .

21989–1989
De Los Reyes, Ex Parte Joel green
texcrimapp · 2013
2 sentences

2015The COA for the Eight District reasoned that “[w]hile the State points us to a four-factor approach to prejudice that our sister circuit in Houston has taken that assesses a defendant’s probability of success at trial,…, we have previously rejected a solely merits-based prejudice analysis, recognizing that ‘[d]eprivation of a trial’ stemming from a Padilla violation ‘is a structural defect, which amounts to a serious denial of the entire judicial proceeding itself, and it demands a presumption of prejudice.’ Ex parte De Los Reyes, 350 S.W.3d 723, 730 (Tex.App.--El Paso 2011, pet. granted), rev

2015The COA for the Eight District reasoned that “[w]hile the State points us to a four-factor approach to prejudice that our sister circuit in Houston has taken that assesses a defendant’s probability of success at trial,…, we have previously rejected a solely merits-based prejudice analysis, recognizing that ‘[d]eprivation of a trial’ stemming from a Padilla violation ‘is a structural defect, which amounts to a serious denial of the entire judicial proceeding itself, and it demands a presumption of prejudice.’ Ex parte De Los Reyes, 350 S.W.3d 723, 730 (Tex.App.--El Paso 2011, pet. granted), rev

12015–2015

Statutes the citing opinions construe

TX § Tex. Penal Code § 6.03 (6) TX § Tex. Penal Code § 38.12 (5)

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

LA 26 (1979–2014) TX 16 (1989–2025) CT 12 (2002–2024) ME 8 (2001–2021) WA 8 (2013–2024) GA 7 (1997–2024) VA 7 (1990–2016) IA 6 (1996–2025) PA 6 (1989–2023) MO 6 (1984–2007) MD 5 (1993–2009) MI 5 (1985–2020) ND 4 (1988–2024) KY 4 (2016–2024) FL 4 (1987–2017) DE 4 (2014–2023) MT 4 (1987–2012) MN 3 (1987–1993) UT 3 (2012–2024) NY 3 (2016–2024) NC 3 (1994–2017) ID 3 (2023–2024) WI 3 (2014–2024) IN 3 (1998–2019) WY 2 (2007–2020) NM 2 (1991–2003) NJ 2 (2017–2025) WV 2 (2000–2011) TN 2 (1999–2013) RI 2 (1999–1999) OR 2 (1979–1981) MS 2 (1986–2018) VT 2 (1989–2005) NH 2 (2013–2017) OH 2 (2019–2020)

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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