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12 Texas opinions name it 3 courts 1976–2025 4 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 |
|---|---|---|
Haliburton v. Stategreen2 sentences2006A single "criminal episode," as defined in Penal Code section 3.01, includes all offenses that form a part of one criminal "transaction." Cobb v. State, 85 S.W.3d 258, 266 (Tex. Crim.App.2002). [5] The purpose of the joinder rule is to achieve "convenience and efficiency, permitting one trial on the joined counts, and treating the separate offenses as one for sentencing purposes." Id. at 265 (citing Haliburton v. State, 578 S.W.2d 726, 729 (Tex.Crim.App.1979)). 2005App. 2002). (3) The purpose of the joinder rule is to achieve "convenience and efficiency, permitting one trial on the joined counts, and treating the separate offenses as one for sentencing purposes." Halliburton v. State , 578 S.W.2d 726, 729 (Tex. Crim. | 3 | 3 |
Smith v. Adairgreen2 sentences2021See Smith, 96 S.W.3d at 708 . 2 The River Authority argued that the Montgomery County plaintiffs affirmatively cannot establish an essential need to maintain their claims in Harris County because numerous other claims have been filed in surrounding counties, including in Montgomery County. 9 Because the Montgomery County plaintiffs did not establish that venue was proper in Harris County, nor did they establish the applicability of section 15.003(a)’s exceptions, we conclude that the trial court erred in denying the River Authority’s motion to dismiss or transfer pursuant to section 15.003. 2020See Smith, 96 S.W.3d at 708 .15 We sustain portions of the Devon Parties’ first and second issues.16 15 We do note however that Iona’s proof of no unfair prejudice and convenience (the second and fourth joinder factors) does not meet its prima facie burden on those factors. | 2 | 2 |
Harding Bars, LLC D/B/A the Aquifer Bar, Bars R US, Inc., and Ramsey White Bars LLC D/B/A Kennedy's Public House v. Kayle McCaskillgreen1 sentence2025The Fourth Court of Appeals has correctly recognized the limited scope of Section 15.003, holding that interlocutory appeals are available “only to plaintiffs who are unable to independently establish venue apart from the joinder factors set out in [S]ection 15.003(a).” Basic Energy, 398 S.W.3d at 736 ; see also Harding Bars, LLC v. McCaskill, 374 S.W.3d 517 , 519–20 (Tex. App.—San Antonio 2012, pet. denied). | 1 | 1 |
Basic Energy Services GP, LLC and Basic Energy Services, L.P. v. Nelda Gomez, Duly Appointed Legal Guardian of the Estate of Kayla Deanne Lazo (Minor)green1 sentence2010In our abatement opinion, we recognized that this “limited right of interlocutory appeal extends only to plaintiffs who are unable to independently establish proper venue apart from the joinder factors set out in section 15.003(a).” -3- 04-10-00128-CV Basic Energy, 2010 WL 2770276, at *2 (citing TEX. | 1 | 1 |
Cobb v. Stategreen2 sentences2006A single "criminal episode," as defined in Penal Code section 3.01, includes all offenses that form a part of one criminal "transaction." Cobb v. State, 85 S.W.3d 258, 266 (Tex. Crim.App.2002). [5] The purpose of the joinder rule is to achieve "convenience and efficiency, permitting one trial on the joined counts, and treating the separate offenses as one for sentencing purposes." Id. at 265 (citing Haliburton v. State, 578 S.W.2d 726, 729 (Tex.Crim.App.1979)). 2006A single "criminal episode," as defined in Penal Code section 3.01, includes all offenses that form a part of one criminal "transaction." Cobb v. State, 85 S.W.3d 258, 266 (Tex. Crim.App.2002). [5] The purpose of the joinder rule is to achieve "convenience and efficiency, permitting one trial on the joined counts, and treating the separate offenses as one for sentencing purposes." Id. at 265 (citing Haliburton v. State, 578 S.W.2d 726, 729 (Tex.Crim.App.1979)). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Williams v. Saxon
green
2 sentences2025The Fourth Court of Appeals explained that because of the joinder requirement, “the homestead interest in property solely in the name of one spouse only would clearly fall within the rules governing joint management property.” Williams v. Saxon, 521 S.W.2d 88 , 90–91 (Tex. App.—San Antonio 1975, writ ref’d n.r.e.). 2025The Fourth Court of Appeals explained that because of the joinder requirement, “the homestead interest in property solely in the name of one spouse only would clearly fall within the rules governing joint management property.” Williams v. Saxon, 521 S.W.2d 88 , 90–91 (Tex. App.—San Antonio 1975, writ ref’d n.r.e.). 11 Anna and Jose attempt to avoid this result by arguing that the property was not a homestead because both Jeanette and Louis abandoned the homestead. | 2 | 2025–2025 |
Petroleum Anchor Equipment, Inc. v. Tyra
green
1 sentence2017However, the case he cites in support of his argument, Petroleum Anchor Equipment, Inc. v. Tyra, 406 S.W.2d 891 (Tex. 1966), is inapplicable because it was overruled in part by Cooper v. Texas Gulf Industries, where the Supreme Court of Texas recognized that Rule 39 "initiated an entirely new method for resolving the question of join-der of parties” and "wholly replaced” the joinder analysis used in Petroleum Anchor Equipment. | 1 | 2017–2017 |
Cooper v. Texas Gulf Industries, Inc.
green
1 sentence2017Cooper, 513 S.W.2d at 203 . . | 1 | 2017–2017 |
Amoco Production Co. v. Alexander
green
1 sentence1986The joinder of a claim in contract with a claim in tort does not alter the basic principles: punitive damages are not awarded for breach of contract, Amoco Production Co. v. Alexander, 622 S.W.2d 563, 571 ; the award of damages in tort is a prerequisite to recovery of punitive damages. | 1 | 1986–1986 |
Doubleday & Co., Inc. v. Rogers
green
1 sentence1986Doubleday & Company, Inc. v. Rogers, 674 S.W.2d 751, 753-54 . | 1 | 1986–1986 |
Moore v. Downie Bros. Circus
neutral
1 sentence1976Circus, 164 S.W.2d 420 (Tex.Civ.App., Fort Worth, 1942, no writ hist.). | 1 | 1976–1976 |
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.