burden of disproving defense (Texas) · Go Syfert
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burden of disproving defense in Texas

14 Texas opinions name it 2 courts 1982–2017 0 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 (6)

CaseFollowedCited
Proctor v. Stategreen
texcrimapp · 1998 · cited in 3 Texas opinions naming this issue, 1998–2003
2 sentences

2003The Fort Worth Court of Appeals held that “because the State does not have the burden of disproving a defense the defendant did not bother to raise, appellant waived any error regarding the State's proof and the statute of limitations.” Johnson v. State , 977 S.W.2d 725, 727 (Tex. App.—Fort Worth 1998, pet. ref’d.) ( citing Proctor , 967 S.W.2d at 844-45 ).

2001See Proctor v. State, 967 S.W.2d 840, 844-45 (Tex.Crim.App.1998); Johnson v. State, 977 S.W.2d 725, 727 (Tex.App.—Fort Worth 1998, pet. ref'd).

23
Johnson v. Stategreen
texapp · 1998 · cited in 2 Texas opinions naming this issue, 2001–2003
2 sentences

2003The Fort Worth Court of Appeals held that “because the State does not have the burden of disproving a defense the defendant did not bother to raise, appellant waived any error regarding the State's proof and the statute of limitations.” Johnson v. State , 977 S.W.2d 725, 727 (Tex. App.—Fort Worth 1998, pet. ref’d.) ( citing Proctor , 967 S.W.2d at 844-45 ).

2001See Proctor v. State, 967 S.W.2d 840, 844-45 (Tex.Crim.App.1998); Johnson v. State, 977 S.W.2d 725, 727 (Tex.App.—Fort Worth 1998, pet. ref'd).

22
Jordan v. Honorable Court of Appeals for the Fourth Supreme Judicial Districtgreen
tex · 1985 · cited in 3 Texas opinions naming this issue, 1992–2000
2 sentences

1997See Jordan, 701 S.W.2d at 649-51 (Gonzalez, J., concurring and dissenting). [6] Based on the foregoing, we disavow Fuller to the extent it holds "the party asserting the privilege has the burden of disproving the waiver," and we disapprove of the Court of Appeals' opinion in this case to the extent it holds disclosure of privileged materials by a defendant's lawyer, standing alone, is sufficient to support a finding of waiver.

1997See Jordan, 701 S.W.2d at 649-51 (Gonzalez, J., concurring and dissenting). 6 Based on the foregoing, we disavow Fuller to the extent it holds “the party asserting the privilege has the burden of disproving the waiver,” and we disapprove of the Court of Appeals’ opinion in this ease to the extent it holds disclosure of privileged materials by a defendant’s lawyer, standing alone, is sufficient to support a finding of waiver.

13
Bruno v. Stategreen
texcrimapp · 1993 · cited in 1 Texas opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., In re S.S., 167 S.W.3d 108 , 112–14 (Tex. App.—Waco 2005, no pet.) (State met its burden of disproving the defense where it presented sufficient evidence disproving juvenile’s mistake-of-fact defense in trespass case); Bruno v. State, 812 S.W.2d 56 , 59–60 (Tex. App.—Houston [14th Dist.] 1991), aff’d, 845 S.W.2d 910, 912 (Tex.Crim.App. 1993) (trial court properly instructed jury that the State had the burden of disproving defendant’s mistake of fact defense beyond a reasonable doubt where defendant claimed that he mistakenly believed that he had consent to operate the victim’s vehic

11
In Re SSgreen
texapp · 2005 · cited in 1 Texas opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., In re S.S., 167 S.W.3d 108 , 112–14 (Tex. App.—Waco 2005, no pet.) (State met its burden of disproving the defense where it presented sufficient evidence disproving juvenile’s mistake-of-fact defense in trespass case); Bruno v. State, 812 S.W.2d 56 , 59–60 (Tex. App.—Houston [14th Dist.] 1991), aff’d, 845 S.W.2d 910, 912 (Tex.Crim.App. 1993) (trial court properly instructed jury that the State had the burden of disproving defendant’s mistake of fact defense beyond a reasonable doubt where defendant claimed that he mistakenly believed that he had consent to operate the victim’s vehic

11
Carmona v. Stategreen
texapp · 1994 · cited in 1 Texas opinions naming this issue, 1997–1997
2 sentences

1997See id.

1997See id.

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 (5)

CaseCitedYears
Saxton v. State green
texcrimapp · 1991
2 sentences

2015Id.

2003Id.

22003–2015
Zuliani v. State green
texcrimapp · 2003
2 sentences

2012Zuliani, 97 S.W.3d at 594 .

2004Id.

22004–2012
Fuller v. State green
texapp · 1992
2 sentences

2000Fuller, 835 S.W.2d at 769 , citing Jordan v. Court of Appeals for the Fourth Supreme Judicial District, 701 S.W.2d 644 (Tex.1985), and State ex rel.

1994Fuller, 835 S.W.2d at 769 .

21994–2000
Bush v. State green
texcrimapp · 1981
2 sentences

1983Bush v. State, 611 S.W.2d 428 (Tex.Cr.App.1980).

1982Bush v. State, 611 S.W.2d at 430 .

21982–1983
Bruno v. State green
texapp · 1991
1 sentence

2017See, e.g., In re S.S., 167 S.W.3d 108 , 112–14 (Tex. App.—Waco 2005, no pet.) (State met its burden of disproving the defense where it presented sufficient evidence disproving juvenile’s mistake-of-fact defense in trespass case); Bruno v. State, 812 S.W.2d 56 , 59–60 (Tex. App.—Houston [14th Dist.] 1991), aff’d, 845 S.W.2d 910, 912 (Tex.Crim.App. 1993) (trial court properly instructed jury that the State had the burden of disproving defendant’s mistake of fact defense beyond a reasonable doubt where defendant claimed that he mistakenly believed that he had consent to operate the victim’s vehic

12017–2017

Where else courts name it

GA 55 (1991–2026) NY 42 (1908–2020) PA 29 (1987–2026) CT 26 (1982–2021) OR 21 (1973–2026) IN 19 (1983–2017) TX 14 (1982–2017) MI 12 (1958–2020) IL 12 (1977–2022) WA 12 (1978–2022) ND 12 (1971–1994) HI 9 (1995–2020) NJ 8 (1977–2021) MA 7 (1978–2025) AL 7 (2013–2023) MN 4 (1978–2002) FL 3 (1992–2012) IA 3 (1910–2021) KS 2 (2018–2019) LA 2 (1984–1999) WY 2 (2011–2024) MD 2 (2019–2019) CA 2 (2006–2025) ME 2 (2020–2020)

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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