strict-scrutiny analysis (Texas) · Go Syfert
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strict-scrutiny analysis in Texas

16 Texas opinions name it 3 courts 2001–2024 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 (17)

CaseFollowedCited
City of Cleburne v. Cleburne Living Center, Inc.green
scotus · 1985 · cited in 4 Texas opinions naming this issue, 2007–2018
2 sentences

2018City of Cleburne, Tex. v. Cleburne Living Ctr., 473 U.S. 432, 440 (1985); Schlittler v. State, 488 S.W.3d 306, 316 (Tex. Crim.

2010City of Cleburne, 473 U.S. at 439-40 , 105 S.Ct. 3249 ; Cannady v. State, 11 S.W.3d 205, 215 (Tex.Crim.App.2000); Kiss v. State, 316 S.W.3d 665, 668-69 (Tex.App.-Dallas 2009, pet. ref'd).

34
Troxel v. Granvillegreen
scotus · 2000 · cited in 3 Texas opinions naming this issue, 2006–2020
2 sentences

2020Id. at 80 .

2006Id. at 80 , 120 S.Ct. 2054 .

13
Reed v. Town of Gilbertgreen
scotus · 2015 · cited in 2 Texas opinions naming this issue, 2016–2020
2 sentences

2020In applying the strict-scrutiny standard to former subsection (b)(1)—and holding that it did not survive strict scrutiny and was unconstitutional on its face in violation of the First Amendment— the Thompson court nevertheless provided some limiting guideposts.4 As an that interest.”); see also Nat’l Inst. of Family & Life Advocates v. Becerra, 138 S. Ct. 2361, 2374 (2018) (citing Reed, 135 S. Ct. at 2228 , and discussing Court’s application of strict scrutiny to content-based laws seeking to regulate speech in various professional fields). 4 See Murray v. State, 261 S.W.3d 255, 257 (Tex. App.

2016Strict scrutiny Under a strict-scrutiny analysis, which has been described as “‘strict’ in theory but usually ‘fatal’ in fact,’”89 the government has the burden of proving that the restriction furthers a 86 Id. 87 See Reed, 135 S. Ct. at 2228 . 88 See Barstow v. State, 742 S.W.2d 495 , 501 n.2 (Tex. App.—Austin 1987, writ denied) (“On questions of federal law . . . all courts in every state owe obedience to the Supreme Court of the United States.”); see also Penrod Drilling Corp. v. Williams, 868 S.W.2d 294, 296 (Tex. 1993) (Texas courts “are obligated to follow only higher Texas courts and th

12
Reno v. American Civil Liberties Uniongreen
scotus · 1997 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See Reno v. ACLU, 521 U.S. 844, 879 (1997) (“The breadth of this content-based restriction of speech imposes an especially heavy burden on the Government to explain why a less restrictive provision would not be as effective as the CDA.”).

11
cluster 2144green
· · cited in 1 Texas opinions naming this issue, 2021–2021
2 sentences

2021But the First Amendment’s overbreadth doctrine allows a court to declare a law unconstitutional on its face “even if it may have some legitimate application and even if the parties before the court were not engaged in activity protected by the First Amendment.” Id. at 864–65 (first citing United States v. Stevens, 559 U.S. 460, 473 , 130 S. Ct. 1577, 1587 (2010); and then Sabri v. United States, 541 U.S. 600 , 609–10, 124 S. Ct. 1941 , 1948–49 (2004)). 7 that Section 36.063 is a content-based restriction on speech, is subject to a strict- scrutiny analysis, forbids protected speech, and fails

2021But the First Amendment’s overbreadth doctrine allows a court to declare a law unconstitutional on its face “even if it may have some legitimate application and even if the parties before the court were not engaged in activity protected by the First Amendment.” Id. at 864–65 (first citing United States v. Stevens, 559 U.S. 460, 473 , 130 S. Ct. 1577, 1587 (2010); and then Sabri v. United States, 541 U.S. 600 , 609–10, 124 S. Ct. 1941 , 1948–49 (2004)). 7 that Section 36.063 is a content-based restriction on speech, is subject to a strict- scrutiny analysis, forbids protected speech, and fails

11
Murray, Raymond Desmondgreen
texcrimapp · 2009 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020In applying the strict-scrutiny standard to former subsection (b)(1)—and holding that it did not survive strict scrutiny and was unconstitutional on its face in violation of the First Amendment— the Thompson court nevertheless provided some limiting guideposts.4 As an that interest.”); see also Nat’l Inst. of Family & Life Advocates v. Becerra, 138 S. Ct. 2361, 2374 (2018) (citing Reed, 135 S. Ct. at 2228 , and discussing Court’s application of strict scrutiny to content-based laws seeking to regulate speech in various professional fields). 4 See Murray v. State, 261 S.W.3d 255, 257 (Tex. App.

11
National Institute of Family and Life Advocates v. Becerragreen
scotus · 2018 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020In applying the strict-scrutiny standard to former subsection (b)(1)—and holding that it did not survive strict scrutiny and was unconstitutional on its face in violation of the First Amendment— the Thompson court nevertheless provided some limiting guideposts.4 As an that interest.”); see also Nat’l Inst. of Family & Life Advocates v. Becerra, 138 S. Ct. 2361, 2374 (2018) (citing Reed, 135 S. Ct. at 2228 , and discussing Court’s application of strict scrutiny to content-based laws seeking to regulate speech in various professional fields). 4 See Murray v. State, 261 S.W.3d 255, 257 (Tex. App.

11
Murray v. Stategreen
texapp · 2008 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020In applying the strict-scrutiny standard to former subsection (b)(1)—and holding that it did not survive strict scrutiny and was unconstitutional on its face in violation of the First Amendment— the Thompson court nevertheless provided some limiting guideposts.4 As an that interest.”); see also Nat’l Inst. of Family & Life Advocates v. Becerra, 138 S. Ct. 2361, 2374 (2018) (citing Reed, 135 S. Ct. at 2228 , and discussing Court’s application of strict scrutiny to content-based laws seeking to regulate speech in various professional fields). 4 See Murray v. State, 261 S.W.3d 255, 257 (Tex. App.

11
Rangra v. Browngreen
ca5 · 2009 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018Rangra v. Brown, 566 F.3d 515, 521 (5th Cir. 2009) (“A speech regulation is content-based if it defines the regulated speech by reference to its content”; agreeing that the criminal provisions of TOMA are “content-based regulations that require the state to satisfy the strict-scrutiny test in order to uphold them.”).

11
Schlittler v. Stategreen
texcrimapp · 2016 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018City of Cleburne, Tex. v. Cleburne Living Ctr., 473 U.S. 432, 440 (1985); Schlittler v. State, 488 S.W.3d 306, 316 (Tex. Crim.

11
Barstow v. Stategreen
texapp · 1987 · cited in 1 Texas opinions naming this issue, 2016–2016
2 sentences

2016Strict scrutiny Under a strict-scrutiny analysis, which has been described as “‘strict’ in theory but usually ‘fatal’ in fact,’”89 the government has the burden of proving that the restriction furthers a 86 Id. 87 See Reed, 135 S. Ct. at 2228 . 88 See Barstow v. State, 742 S.W.2d 495 , 501 n.2 (Tex. App.—Austin 1987, writ denied) (“On questions of federal law . . . all courts in every state owe obedience to the Supreme Court of the United States.”); see also Penrod Drilling Corp. v. Williams, 868 S.W.2d 294, 296 (Tex. 1993) (Texas courts “are obligated to follow only higher Texas courts and th

2016Strict scrutiny Under a strict-scrutiny analysis, which has been described as “‘strict’ in theory but usually ‘fatal’ in fact,’”89 the government has the burden of proving that the restriction furthers a 86 Id. 87 See Reed, 135 S. Ct. at 2228 . 88 See Barstow v. State, 742 S.W.2d 495 , 501 n.2 (Tex. App.—Austin 1987, writ denied) (“On questions of federal law . . . all courts in every state owe obedience to the Supreme Court of the United States.”); see also Penrod Drilling Corp. v. Williams, 868 S.W.2d 294, 296 (Tex. 1993) (Texas courts “are obligated to follow only higher Texas courts and th

11
Penrod Drilling Corp. v. Williamsgreen
tex · 1993 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016Strict scrutiny Under a strict-scrutiny analysis, which has been described as “‘strict’ in theory but usually ‘fatal’ in fact,’”89 the government has the burden of proving that the restriction furthers a 86 Id. 87 See Reed, 135 S. Ct. at 2228 . 88 See Barstow v. State, 742 S.W.2d 495 , 501 n.2 (Tex. App.—Austin 1987, writ denied) (“On questions of federal law . . . all courts in every state owe obedience to the Supreme Court of the United States.”); see also Penrod Drilling Corp. v. Williams, 868 S.W.2d 294, 296 (Tex. 1993) (Texas courts “are obligated to follow only higher Texas courts and th

11
Bernal v. Faintergreen
scotus · 1984 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016Strict scrutiny Under a strict-scrutiny analysis, which has been described as “‘strict’ in theory but usually ‘fatal’ in fact,’”89 the government has the burden of proving that the restriction furthers a 86 Id. 87 See Reed, 135 S. Ct. at 2228 . 88 See Barstow v. State, 742 S.W.2d 495 , 501 n.2 (Tex. App.—Austin 1987, writ denied) (“On questions of federal law . . . all courts in every state owe obedience to the Supreme Court of the United States.”); see also Penrod Drilling Corp. v. Williams, 868 S.W.2d 294, 296 (Tex. 1993) (Texas courts “are obligated to follow only higher Texas courts and th

11
Armando Salgado v. Stategreen
texapp · 2016 · cited in 1 Texas opinions naming this issue, 2016–2016
2 sentences

2016See Salgado, 492 S.W.3d at 396 .

2016See Salgado, 492 S.W.3d at 397 (concluding the online- solicitation statute is a conduct-based statute, that it does not criminalize protected speech, and that the statute, given the speech at issue, was not subject to a strict- scrutiny analysis).

11
Kunz v. New Yorkgreen
scotus · 1951 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015Other Factors Suggest that a Police-Imposed Restriction, Even if Content-Neutral, Is Subject to Strict Scrutiny One reason the Madsen court declined to impose the strict-scrutiny standard in the injunction 31 Kunz v. New York, 340 U.S. 290 (1951). 32 Id. at 294-95 . 33 Id. at 296 (Justice Jackson dissenting). 34 Id. 35 Id. at 294-95 (Court’s op.). 36 Id.

2015Other Factors Suggest that a Police-Imposed Restriction, Even if Content-Neutral, Is Subject to Strict Scrutiny One reason the Madsen court declined to impose the strict-scrutiny standard in the injunction 31 Kunz v. New York, 340 U.S. 290 (1951). 32 Id. at 294-95 . 33 Id. at 296 (Justice Jackson dissenting). 34 Id. 35 Id. at 294-95 (Court’s op.). 36 Id.

11
Kiss v. Stategreen
texapp · 2010 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010City of Cleburne, 473 U.S. at 439-40 , 105 S.Ct. 3249 ; Cannady v. State, 11 S.W.3d 205, 215 (Tex.Crim.App.2000); Kiss v. State, 316 S.W.3d 665, 668-69 (Tex.App.-Dallas 2009, pet. ref'd).

11
Cannady v. Stategreen
texcrimapp · 2000 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010City of Cleburne, 473 U.S. at 439-40 , 105 S.Ct. 3249 ; Cannady v. State, 11 S.W.3d 205, 215 (Tex.Crim.App.2000); Kiss v. State, 316 S.W.3d 665, 668-69 (Tex.App.-Dallas 2009, pet. ref'd).

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 (10)

CaseCitedYears
Board of Trustees of Univ. of Ala. v. Garrett green
scotus · 2001
2 sentences

2007“Under rational-basis review, where a group possesses ‘distinguishing characteristics relevant to interests the State has the authority to implement,’ a State’s decision to act on the basis of those differences does not give rise to a constitutional violation.” Bd. of Trustees v. Garrett, 531 U.S. 356, 366-67 , 121 S.Ct. 955, 963 , 148 L.Ed.2d 866 (2001) (quoting City of Cleburne, 473 U.S. at 441 , 105 S.Ct. at 3255 ). “ ‘Such a classification cannot run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and some legitimate governmental

2007“Under rational-basis review, where a group possesses ‘distinguishing characteristics relevant to interests the State has the authority to implement,’ a State’s decision to act on the basis of those differences does not give rise to a constitutional violation.” Bd. of Trustees v. Garrett, 531 U.S. 356, 366-67 , 121 S.Ct. 955, 963 , 148 L.Ed.2d 866 (2001) (quoting City of Cleburne, 473 U.S. at 441 , 105 S.Ct. at 3255 ). “ ‘Such a classification cannot run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and some legitimate governmental

22007–2007
Sabri v. United States green
scotus · 2004
2 sentences

2021But the First Amendment’s overbreadth doctrine allows a court to declare a law unconstitutional on its face “even if it may have some legitimate application and even if the parties before the court were not engaged in activity protected by the First Amendment.” Id. at 864–65 (first citing United States v. Stevens, 559 U.S. 460, 473 , 130 S. Ct. 1577, 1587 (2010); and then Sabri v. United States, 541 U.S. 600 , 609–10, 124 S. Ct. 1941 , 1948–49 (2004)). 7 that Section 36.063 is a content-based restriction on speech, is subject to a strict- scrutiny analysis, forbids protected speech, and fails

2021But the First Amendment’s overbreadth doctrine allows a court to declare a law unconstitutional on its face “even if it may have some legitimate application and even if the parties before the court were not engaged in activity protected by the First Amendment.” Id. at 864–65 (first citing United States v. Stevens, 559 U.S. 460, 473 , 130 S. Ct. 1577, 1587 (2010); and then Sabri v. United States, 541 U.S. 600 , 609–10, 124 S. Ct. 1941 , 1948–49 (2004)). 7 that Section 36.063 is a content-based restriction on speech, is subject to a strict- scrutiny analysis, forbids protected speech, and fails

12021–2021
Broadrick v. Oklahoma green
scotus · 1973
1 sentence

2021But the First Amendment’s overbreadth doctrine allows a court to declare a law unconstitutional on its face “even if it may have some legitimate application and even if the parties before the court were not engaged in activity protected by the First Amendment.” Id. at 864–65 (first citing United States v. Stevens, 559 U.S. 460, 473 , 130 S. Ct. 1577, 1587 (2010); and then Sabri v. United States, 541 U.S. 600 , 609–10, 124 S. Ct. 1941 , 1948–49 (2004)). 7 that Section 36.063 is a content-based restriction on speech, is subject to a strict- scrutiny analysis, forbids protected speech, and fails

12021–2021
Thompson, Ex Parte Ronald green
texcrimapp · 2014
2 sentences

2020App. 2009). 8 example, the Thompson court indicated that then-in-effect section 21.15(b)(2) would indeed meet the strict-scrutiny standard: One need only look at the next subsection of the statute— § 21.15(b)(2)—to see an example of a provision that is in fact narrowly drawn to protect substantial privacy interests—the provision that makes it a crime to “photograph or . . . record[ ] . . . a visual image of another at a location that is a bathroom or private dressing room.” 442 S.W.3d at 348–49 (alterations in original) (quoting 2007 Tex. Penal Code § 21.15(b)(2)); see Act of May 18, 2007, 80t

2020App. 2009). 8 example, the Thompson court indicated that then-in-effect section 21.15(b)(2) would indeed meet the strict-scrutiny standard: One need only look at the next subsection of the statute— § 21.15(b)(2)—to see an example of a provision that is in fact narrowly drawn to protect substantial privacy interests—the provision that makes it a crime to “photograph or . . . record[ ] . . . a visual image of another at a location that is a bathroom or private dressing room.” 442 S.W.3d at 348–49 (alterations in original) (quoting 2007 Tex. Penal Code § 21.15(b)(2)); see Act of May 18, 2007, 80t

12020–2020
Lo, Ex Parte John Christopher green
texcrimapp · 2013
1 sentence

2018Ex parte Lo, 424 S.W.3d at 15 .

12018–2018
Estes v. State green
texcrimapp · 2018
1 sentence

2018The court of criminal appeals reversed our Estes I judgment and remanded Estes’s appeal to us to consider Estes’s remaining constitutional issues: (1) whether a strict-scrutiny analysis applies to Estes’s equal-protection claim and (2) whether section 22.011(f) violated Estes’s substantive due-process rights.5 Id. at 706 & n.114. 4 Estes did not raise a facial challenge to section 22.011(f), only an as-applied challenge.

12018–2018
City of Renton v. Playtime Theatres, Inc. green
scotus · 1986
1 sentence

2016Strict scrutiny Under a strict-scrutiny analysis, which has been described as “‘strict’ in theory but usually ‘fatal’ in fact,’”89 the government has the burden of proving that the restriction furthers a 86 Id. 87 See Reed, 135 S. Ct. at 2228 . 88 See Barstow v. State, 742 S.W.2d 495 , 501 n.2 (Tex. App.—Austin 1987, writ denied) (“On questions of federal law . . . all courts in every state owe obedience to the Supreme Court of the United States.”); see also Penrod Drilling Corp. v. Williams, 868 S.W.2d 294, 296 (Tex. 1993) (Texas courts “are obligated to follow only higher Texas courts and th

12016–2016
Heller v. Doe Ex Rel. Doe green
scotus · 1993
2 sentences

2007“Under rational-basis review, where a group possesses ‘distinguishing characteristics relevant to interests the State has the authority to implement,’ a State’s decision to act on the basis of those differences does not give rise to a constitutional violation.” Bd. of Trustees v. Garrett, 531 U.S. 356, 366-67 , 121 S.Ct. 955, 963 , 148 L.Ed.2d 866 (2001) (quoting City of Cleburne, 473 U.S. at 441 , 105 S.Ct. at 3255 ). “ ‘Such a classification cannot run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and some legitimate governmental

2007“Under rational-basis review, where a group possesses ‘distinguishing characteristics relevant to interests the State has the authority to implement,’ a State’s decision to act on the basis of those differences does not give rise to a constitutional violation.” Bd. of Trustees v. Garrett, 531 U.S. 356, 366-67 , 121 S.Ct. 955, 963 , 148 L.Ed.2d 866 (2001) (quoting City of Cleburne, 473 U.S. at 441 , 105 S.Ct. at 3255 ). “ ‘Such a classification cannot run afoul of the Equal Protection Clause if there is a rational relationship between the disparity of treatment and some legitimate governmental

12007–2007
Employment Div., Dept. of Human Resources of Ore. v. Smith red
scotus · 1990
1 sentence

2002Id. at 885 .

12002–2002
Turner v. Safley green
scotus · 1987
2 sentences

2001Declining to engage in a strict-scrutiny analysis, the Court stated that a regulation is valid if it is “reasonably related to legitimate penological interests.” Id. at 89 , 107 S.Ct. 2254 .

2001Declining to engage in a strict-scrutiny analysis, the Court stated that a regulation is valid if it is “reasonably related to legitimate penological interests.” Id. at 89 , 107 S.Ct. 2254 .

12001–2001

Where else courts name it

OH 29 (1998–2026) AL 18 (1999–2015) TX 16 (2001–2024) IL 14 (1981–2020) AR 8 (2002–2020) CA 5 (1984–2025) ME 5 (2013–2025) NJ 5 (1992–2002) FL 4 (1991–2014) WI 4 (2000–2014) IA 4 (1981–2026) MT 4 (1997–2025) PA 3 (2020–2026) MN 3 (2011–2024) DE 3 (2023–2025) UT 3 (2015–2021) OR 2 (2001–2003) MI 2 (2011–2022) OK 2 (1986–1998)

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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