grammatical analysis (Texas) · Go Syfert
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grammatical analysis in Texas

14 Texas opinions name it 2 courts 1988–2025 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 (13)

CaseFollowedCited
S & P CONSULTING ENGINEERS, PLLC v. Bakergreen
texapp · 2011 · cited in 3 Texas opinions naming this issue, 2009–2011
2 sentences

2011The S & P Consulting Engineers court chose to rectify this apparent contradiction by disregarding a grammatical rule of construction and deciding that the adjective “negligent” only modified “act,” rather than “act, error, or omission” in Section 150.002(a). 334 S.W.3d at 403 (allowing a certificate to delineate either a negligent “act” or in a non-negligence case the “error or omission”).

2011The S & P Consulting Engineers court chose to rectify this apparent contradiction by disregarding a grammatical rule of construction and deciding that the adjective ―negligent‖ only modified ―act,‖ rather than ―act, error, or omission‖ in Section 150.002(a). 334 S.W.3d at 403 (allowing a certificate to delineate either a negligent ―act‖ or in a non-negligence case the ―error or omission‖).

33
Wallace v. Stategreen
texcrimapp · 1977 · cited in 2 Texas opinions naming this issue, 2013–2013
2 sentences

2013See Harris, 359 S.W.3d at 630 (stating that a grammatical analysis suggests that the unit of prosecution for indecency with a child by exposure is the exposure and, ultimately, adopting that viewpoint); Pizzo, 235 S.W.3d at 718 (holding that three phrases contained within the same subsection of the indecency-with-a-ehild statute defined three separate offenses for jury-unanimity purposes when separated in the disjunctive); see also Wallace v. State, 550 S.W.2d 89, 91 (Tex.Crim.App.1977).

2013See Harris, 359 S.W.3d at 630 (stating that a grammatical analysis suggests that the unit of prosecution for indecency with a child by exposure is the exposure and, ultimately, adopting that viewpoint); Pizzo, 235 S.W.3d at 718 (holding that three phrases contained within the same subsection of the indecency-with-a-child statute defined three separate offenses for jury-unanimity purposes when separated in the disjunctive); see also Wallace v. State, 550 S.W.2d 89 , 91 Loving–13 (Tex. Crim.

22
Pizzo v. Stategreen
texcrimapp · 2007 · cited in 2 Texas opinions naming this issue, 2013–2013
2 sentences

2013See Harris, 359 S.W.3d at 630 (stating that a grammatical analysis suggests that the unit of prosecution for indecency with a child by exposure is the exposure and, ultimately, adopting that viewpoint); Pizzo, 235 S.W.3d at 718 (holding that three phrases contained within the same subsection of the indecency-with-a-ehild statute defined three separate offenses for jury-unanimity purposes when separated in the disjunctive); see also Wallace v. State, 550 S.W.2d 89, 91 (Tex.Crim.App.1977).

2013See Harris, 359 S.W.3d at 630 (stating that a grammatical analysis suggests that the unit of prosecution for indecency with a child by exposure is the exposure and, ultimately, adopting that viewpoint); Pizzo, 235 S.W.3d at 718 (holding that three phrases contained within the same subsection of the indecency-with-a-child statute defined three separate offenses for jury-unanimity purposes when separated in the disjunctive); see also Wallace v. State, 550 S.W.2d 89 , 91 Loving–13 (Tex. Crim.

22
Harris, Owen Thomasgreen
texcrimapp · 2011 · cited in 2 Texas opinions naming this issue, 2013–2013
2 sentences

2013See Harris, 359 S.W.3d at 630 (stating that a grammatical analysis suggests that the unit of prosecution for indecency with a child by exposure is the exposure and, ultimately, adopting that viewpoint); Pizzo, 235 S.W.3d at 718 (holding that three phrases contained within the same subsection of the indecency-with-a-ehild statute defined three separate offenses for jury-unanimity purposes when separated in the disjunctive); see also Wallace v. State, 550 S.W.2d 89, 91 (Tex.Crim.App.1977).

2013See Harris, 359 S.W.3d at 630 (stating that a grammatical analysis suggests that the unit of prosecution for indecency with a child by exposure is the exposure and, ultimately, adopting that viewpoint); Pizzo, 235 S.W.3d at 718 (holding that three phrases contained within the same subsection of the indecency-with-a-child statute defined three separate offenses for jury-unanimity purposes when separated in the disjunctive); see also Wallace v. State, 550 S.W.2d 89 , 91 Loving–13 (Tex. Crim.

22
Zuniga v. Stategreen
· 2018 · cited in 1 Texas opinions naming this issue, 2025–2025
1 sentence

2025See Zuniga v. State, 551 S.W.3d 729, 735 (Tex. Crim.

11
Almanza v. Stategreen
texcrimapp · 1985 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018See Almanza, 686 S.W.2d at 171 ; Taylor, 332 S.W.3d at 490 . 10 V.

11
Barnhart v. Thomasgreen
scotus · 2003 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015See Barnhart v. Thomas, 540 U.S. 20, 26 , 124 S. Ct. 376, 380 (2003). 8 usage is not separate from textual meaning.”); Gen.

2015See Barnhart v. Thomas, 540 U.S. 20, 26 , 124 S. Ct. 376, 380 (2003). 8 usage is not separate from textual meaning.”); Gen.

11
Horseshoe Bay Resort, Ltd. v. CRVI CDP Portfolio, LLCgreen
texapp · 2013 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Goodman et al., The Rodney Dangerfield Clauses: Ten Lease Provisions That Get No Respect, 24 Prob. & Prop. 47, 49 (2010) (“When surrender provisions are litigated, a court will likely interpret the surrender provision in the context of the lease as a whole.”) In the surrender covenant, LeComte must return the hanger to Foster in the same condition as when received, “allowing for reasonable use and wear and damages by acts of God, including fire and storms.” The clause “including fire and storms” directly follows and only modifies “damages by acts of God” under the grammatical rule of the last

11
Hogue v. Stategreen
texcrimapp · 1986 · cited in 1 Texas opinions naming this issue, 1988–1988
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11
Livingston v. Stategreen
texcrimapp · 1976 · cited in 1 Texas opinions naming this issue, 1988–1988
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11
White v. Stategreen
texcrimapp · 1976 · cited in 1 Texas opinions naming this issue, 1988–1988
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11
Jordan v. Stategreen
texcrimapp · 1986 · cited in 1 Texas opinions naming this issue, 1988–1988
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11
Morin v. Stategreen
texcrimapp · 1983 · cited in 1 Texas opinions naming this issue, 1988–1988
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

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 (9)

CaseCitedYears
Jones v. State green
texcrimapp · 2010
2 sentences

2011Another aspect of grammar indicating the gravamen of the offense “is that a legislative reference to an item in the singular suggests that each instance of that item is a separate unit of prosecution.” Jones, 323 S.W.3d at 891 .

2011Another aspect of grammar indicating the gravamen of the offense “is that a legislative reference to an item in the singular suggests that each instance of that item is a separate unit of prosecution.” Jones, 323 S.W.3d at 891 .

32011–2011
Texas Health Presbyterian Hospital of Denton, Marc Wilson, M.D., and Alliance ob/gyn Specialists, Pllc D/B/A ob/gyn Specialists, Pllc v. D.A. and M.A., Individually and as Next Friends of A.A., a Minor green
tex · 2018
1 sentence

2024Id. (quoting Tex. W.

12024–2024
Lefevers v. State green
texcrimapp · 2000
1 sentence

2022As we said in Lefevers, “[e]ach of the enumerated actions involves genital contact [or] anal contact,” giving “‘ultimate sex act’ a meaning readily comprehended by the average person.” Lefevers, 20 S.W.3d at 712 .

12022–2022
Taylor v. State green
texcrimapp · 2011
1 sentence

2018See Almanza, 686 S.W.2d at 171 ; Taylor, 332 S.W.3d at 490 . 10 V.

12018–2018
Russell v. State green
texcrimapp · 1983
1 sentence

1988Because we find that Russell, supra, is on point with the instant case, we overrule appellant’s fourteenth and final point of error.

11988–1988
White v. Texas green
scotus · 1977
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11988–1988
Livingston v. Texas green
scotus · 1977
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11988–1988
Hill v. Mississippi green
scotus · 1977
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11988–1988
Owens v. Meanor green
scotus · 1977
1 sentence

1988Cf. White v. State, 543 S.W.2d 104, 106 (Tex.Cr.App.1976), cert. denied, 430 U.S. 988 , 97 S.Ct. 1689 , 52 L.Ed.2d 384 (1977) (Grammatical error in the indictment did not mislead defendant or deny him fair notice of the offense with which he was charged.); Jordan v. State, 707 S.W.2d 641, 644 (Tex.Cr.App.1986); Livingston v. State, 542 S.W.2d 655, 658 (Tex.Cr.App.1976), cert. denied, 431 U.S. 933 , 97 S.Ct. 2642 , 53 L.Ed.2d 250 (1977) (Ownership of property need not be alleged in a capital murder indictment which alleges the murder occurred during the course of a robbery); Hogue v. State, 711

11988–1988

Statutes the citing opinions construe

TX § Tex. Penal Code § 21.11 (5) TX § Tex. Penal Code § 6.03 (3)

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

TX 14 (1988–2025) CA 10 (1939–2003) MI 10 (1976–2021) OR 5 (2010–2024) MN 4 (2010–2025) IL 3 (1974–1977) OH 3 (1999–2026) GA 3 (1978–2022) PA 3 (1935–2009) IN 2 (1942–1991) VA 2 (1995–2007) WA 2 (2013–2013) NY 2 (1871–1939) UT 2 (2010–2021) WV 2 (2008–2022)

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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