three part test (Texas) · Go Syfert
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three part test in Texas

80 Texas opinions name it 4 courts 1974–2024 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.

Followed or applied (27)

CaseFollowedCited
John C. Trotter v. Jack Anderson Enterprises, Inc. And Jack Andersongreen
ca5 · 1987 · cited in 3 Texas opinions naming this issue, 2011–2021
2 sentences

2021In WFAA-TV, Inc. v. McLemore, the Texas Supreme Court adopted a three- part test to determine if an individual is a limited public figure. (1) the controversy at issue must be public both in the sense that people are discussing it and people other than the immediate participants in the controversy are likely to feel the impact of its resolution; (2) the plaintiff must have more than a trivial or tangential role in the controversy; and (3) the alleged defamation must be germane to the plaintiff's participation in the controversy. 978 S.W.2d 568, 571 (Tex. 1998) (citing Trotter v. Jack Anderson

2011McLemore, 978 S.W.2d at 571 (quoting Trotter v. Jack Anderson Enters., Inc., 818 F.2d 431, 433-34 (5th Cir.1987)).

33
WFAA-TV, Inc. v. McLemoregreen
tex · 1998 · cited in 4 Texas opinions naming this issue, 2011–2023
2 sentences

2021In WFAA-TV, Inc. v. McLemore, the Texas Supreme Court adopted a three- part test to determine if an individual is a limited public figure. (1) the controversy at issue must be public both in the sense that people are discussing it and people other than the immediate participants in the controversy are likely to feel the impact of its resolution; (2) the plaintiff must have more than a trivial or tangential role in the controversy; and (3) the alleged defamation must be germane to the plaintiff's participation in the controversy. 978 S.W.2d 568, 571 (Tex. 1998) (citing Trotter v. Jack Anderson

2011Rosenblatt v. Baer, 383 U.S. 75, 88 (1966); WFAA-TV, Inc. v. McLemore, 978 S.W.2d 568, 571 (Tex. 1998). -6- 04-10-00311-CV The Texas Supreme Court applies the three part test adopted by the Fifth Circuit to determine whether an individual is a limited-purpose public figure: (1) the controversy at issue must be public both in the sense that people are discussing it and people other than the immediate participants in the controversy are likely to feel the impact of its resolution; (2) the plaintiff must have more than a trivial or tangential role in the controversy; and (3) the alleged defamatio

24
Labelle v. Stategreen
texcrimapp · 1986 · cited in 2 Texas opinions naming this issue, 1999–2018
2 sentences

2018See id.

1999See id.

22
Williams v. Stategreen
texcrimapp · 2009 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011See Williams v. State, 301 S.W.3d 675, 688 (Tex.Crim.App. 2009).

2011See Williams v. State , 301 S.W.3d 675, 688 (Tex.Crim.App. 2009).

22
Hartman v. Stategreen
texcrimapp · 1997 · cited in 2 Texas opinions naming this issue, 1999–1999
2 sentences

1999He contends that under Texas Rule of Evidence 702 2 and Hartman v. State, 946 S.W.2d 60 (Tex.Crim.App.1997), breath test results are scientific evidence and as such the evidence must be proven reliable by satisfying a three part test: (1) the underlying scientific theory must be valid; (2) the technique applying the theory must be valid; and (3) the technique must have been *838 properly applied on the occasion in question.

1999See Hartman, 946 S.W.2d at 62 .

22
Welch v. Stategreen
texapp · 2011 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See McGruder v. Puckett, 954 F.2d 313, 316 (5th Cir. 1992); Welch v. State, 335 S.W.3d 376, 380 (Tex. App.—Houston [14th Dist.], pet ref’d).

11
Robert McGruder v. Steven W. Puckettgreen
ca5 · 1992 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See McGruder v. Puckett, 954 F.2d 313, 316 (5th Cir. 1992); Welch v. State, 335 S.W.3d 376, 380 (Tex. App.—Houston [14th Dist.], pet ref’d).

11
Presbytery Of New Jersey Of The Orthodox Presbyterian Church v. Whitmangreen
ca3 · 1996 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
Baggett v. Bullittgreen
scotus · 1964 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
High Ol' Times, Inc. v. George Busbee, Governor of Georgiagreen
ca5 · 1980 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
William Pietzsch v. Jim Mattoxgreen
ca5 · 1983 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
cluster 429418green
ca5 · 1984 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
United Fence & Guard Rail Corp. v. Mario M. Cuomo, Franklin E. White, Horace M. Flowers, Howard L. Sheffeygreen
ca2 · 1989 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
Bellotti v. Bairdgreen
scotus · 1976 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
Lehman v. City of Louisvillegreen
ca10 · 1992 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
Cedar Shake and Shingle Bureau Chemco, Inc. Wesco, Inc. v. City of Los Angelesgreen
ca9 · 1993 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016The Second Circuit has a three-part test for Pullman abstention: (1) unclear state law; (2) a constitutional issue based on the construction of the unclear state law; and (3) the unclear state law susceptible to a reasonable interpretation that would avoid the constitutional issue.696 The Third Circuit also has a three part test, with the first two elements embracing the Cuomo test, and a third directed to "state interest": (1) unclear state law underlying federal constitutional claims; (2) subject to state court interpretation that would obviate the need for, or substantially narrow the scope

11
JVA Operating Co. v. Kaiser-Francis Oil Co.green
texapp · 2000 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015In Madden v. State, The Court of Criminal Appeals has set out a three part test for determining whether or not to include a 38.23(a) instruction. 242 11 S.W.3d 504, 510 (Tex. Crim.

11
Rosenblatt v. Baergreen
scotus · 1966 · cited in 1 Texas opinions naming this issue, 2011–2011
1 sentence

2011Rosenblatt v. Baer, 383 U.S. 75, 88 (1966); WFAA-TV, Inc. v. McLemore, 978 S.W.2d 568, 571 (Tex. 1998). -6- 04-10-00311-CV The Texas Supreme Court applies the three part test adopted by the Fifth Circuit to determine whether an individual is a limited-purpose public figure: (1) the controversy at issue must be public both in the sense that people are discussing it and people other than the immediate participants in the controversy are likely to feel the impact of its resolution; (2) the plaintiff must have more than a trivial or tangential role in the controversy; and (3) the alleged defamatio

11
Steele v. City of Houstongreen
tex · 1980 · cited in 1 Texas opinions naming this issue, 2011–2011
1 sentence

2011Steele v. City of Houston, 603 S.W.2d 786, 791 (Tex. 1980).

11
Ginsberg v. Fifth Court of Appealsgreen
tex · 1985 · cited in 1 Texas opinions naming this issue, 1994–1994
11
Fentis v. Stategreen
texcrimapp · 1975 · cited in 1 Texas opinions naming this issue, 1990–1990
11
Bush v. Stategreen
texcrimapp · 1982 · cited in 1 Texas opinions naming this issue, 1990–1990
11
Tippins v. Stategreen
texcrimapp · 1975 · cited in 1 Texas opinions naming this issue, 1990–1990
11
Phillips v. Stategreen
texcrimapp · 1983 · cited in 1 Texas opinions naming this issue, 1990–1990
11
Brown v. Texasgreen
scotus · 1979 · cited in 1 Texas opinions naming this issue, 1989–1989
11
Ibn-Tamas v. United Statesgreen
dc · 1979 · cited in 1 Texas opinions naming this issue, 1985–1985
11
D'Ambra v. United Statesgreen
rid · 1973 · cited in 1 Texas opinions naming this issue, 1979–1979
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 (21)

CaseCitedYears
Solem v. Helm red
scotus · 1983
2 sentences

2024Under the three part test originally set forth in Solem v. Helm, 463 U.S. 277 , 103 S. Ct. 3001 , 77 L.Ed.2d 637 (1983), the proportionality of a sentence is evaluated by considering (1) the gravity of the offense and the harshness of the penalty, (2) the sentences imposed on other criminals in the same jurisdiction, and (3) the sentences imposed for commission of the same crime in other jurisdictions.

2024Under the three part test originally set forth in Solem v. Helm, 463 U.S. 277 , 103 S. Ct. 3001 , 77 L.Ed.2d 637 (1983), the proportionality of a sentence is evaluated by considering (1) the gravity of the offense and the harshness of the penalty, (2) the sentences imposed on other criminals in the same jurisdiction, and (3) the sentences imposed for commission of the same crime in other jurisdictions.

492006–2024
Little v. State green
texcrimapp · 1999
2 sentences

2009The three part test used to determine if a prosecutor's actions have violated due process asks "whether the prosecutor 1) failed to disclose evidence, 2) favorable to the accused, and 3) the evidence is material, meaning there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different." Little , 991 S.W.2d at 866 .

2009The three part test used to determine if a prosecutor’s actions have violated due process asks “whether the prosecutor 1) failed to disclose evidence, 2) favorable to the accused, and 3) the evidence is material, meaning there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” Little, 991 S.W.2d at 866 .

32009–2011
Eric Waldbaum v. Fairchild Publications, Inc green
cadc · 1980
2 sentences

2021In WFAA-TV, Inc. v. McLemore, the Texas Supreme Court adopted a three- part test to determine if an individual is a limited public figure. (1) the controversy at issue must be public both in the sense that people are discussing it and people other than the immediate participants in the controversy are likely to feel the impact of its resolution; (2) the plaintiff must have more than a trivial or tangential role in the controversy; and (3) the alleged defamation must be germane to the plaintiff's participation in the controversy. 978 S.W.2d 568, 571 (Tex. 1998) (citing Trotter v. Jack Anderson

2012Cir. 1980), Scripps claims that “[s]ometimes position alone can make a public figure.” See Waldbaum, 627 F.2d at 1298–1300 (finding that the plaintiff was a limited-purpose public figure and setting out that the three-part test applies).5 Scripps appears to argue that this Court does not need to engage in the three- part test in order to determine whether Carter is a limited-purpose public figure because Carter’s status as CEO of the Chamber of Commerce alone made him a limited- purpose public figure.

22012–2021
Harmelin v. Michigan green
scotus · 1991
2 sentences

2017The application of the Solem test has been modified by Texas courts and the Fifth Circuit Court of Appeals in light of the Supreme Court’s decision in Harmelin v. Michigan, 501 U.S. 957 , 111 S. Ct. 2680 , 115 L.

2017The application of the Solem test has been modified by Texas courts and the Fifth Circuit Court of Appeals in light of the Supreme Court’s decision in Harmelin v. Michigan, 501 U.S. 957 , 111 S. Ct. 2680 , 115 L.

22017–2017
City of Houston v. Scottish Rite Benevolent Ass'n green
· 1921
2 sentences

2017This standard *469 requires an organization to meet a three part test: (1) the organization must make no gain or profit; (2) it must be "organized to accomplish ends wholly benevolent by engaging in humanitarian services maintained to care for the physical or mental well-being of its recipients"; and (3) "[t]he total operation of the charity must affect all the people of a community or state by assuming, to a material extent, services which otherwise might devolve to and become the obligations of the community or state." N. Alamo Water Supply Corp. , 804 S.W.2d at 899 (citing City of McAllen v

2017This standard *469 requires an organization to meet a three part test: (1) the organization must make no gain or profit; (2) it must be "organized to accomplish ends wholly benevolent by engaging in humanitarian services maintained to care for the physical or mental well-being of its recipients"; and (3) "[t]he total operation of the charity must affect all the people of a community or state by assuming, to a material extent, services which otherwise might devolve to and become the obligations of the community or state." N. Alamo Water Supply Corp. , 804 S.W.2d at 899 (citing City of McAllen v

21974–2017
Craddock v. Sunshine Bus Lines, Inc. green
tex · 1939
2 sentences

2003Craddock, 133 S.W.2d at 126 .

2002Id. at 382 citing (Craddock, 133 S.W.2d at 126 ).

22002–2003
Retamco Operating, Inc. v. Republic Drilling Co. green
tex · 2009
1 sentence

2019Retamco, 278 S.W.3d at 339 .

12019–2019
North Alamo Water Supply Corp. v. Willacy County Appraisal District green
tex · 1991
1 sentence

2017This standard *469 requires an organization to meet a three part test: (1) the organization must make no gain or profit; (2) it must be "organized to accomplish ends wholly benevolent by engaging in humanitarian services maintained to care for the physical or mental well-being of its recipients"; and (3) "[t]he total operation of the charity must affect all the people of a community or state by assuming, to a material extent, services which otherwise might devolve to and become the obligations of the community or state." N. Alamo Water Supply Corp. , 804 S.W.2d at 899 (citing City of McAllen v

12017–2017
City of McAllen v. Evangelical Lutheran Good Samaritan Society green
tex · 1975
2 sentences

2017This standard *469 requires an organization to meet a three part test: (1) the organization must make no gain or profit; (2) it must be "organized to accomplish ends wholly benevolent by engaging in humanitarian services maintained to care for the physical or mental well-being of its recipients"; and (3) "[t]he total operation of the charity must affect all the people of a community or state by assuming, to a material extent, services which otherwise might devolve to and become the obligations of the community or state." N. Alamo Water Supply Corp. , 804 S.W.2d at 899 (citing City of McAllen v

2017Applying the first factor, "[t]he law is well settled that the proscription against an institution's realization of 'gain or profit' refers to gain or profit by private individuals or the accrual of distributable profits." City of McAllen , 530 S.W.2d at 809 .

12017–2017
San Antonio Conservation Society, Inc. v. City of San Antonio green
tex · 1970
1 sentence

2017This standard *469 requires an organization to meet a three part test: (1) the organization must make no gain or profit; (2) it must be "organized to accomplish ends wholly benevolent by engaging in humanitarian services maintained to care for the physical or mental well-being of its recipients"; and (3) "[t]he total operation of the charity must affect all the people of a community or state by assuming, to a material extent, services which otherwise might devolve to and become the obligations of the community or state." N. Alamo Water Supply Corp. , 804 S.W.2d at 899 (citing City of McAllen v

12017–2017
Old Republic Insurance Co. v. Scott green
tex · 1994
1 sentence

2002Id. at 382 citing (Craddock, 133 S.W.2d at 126 ).

12002–2002
Republic Insurance Co. v. Davis green
tex · 1993
11994–1994
Thomas v. State green
texcrimapp · 1992
11993–1993
Opdahl v. State green
texcrimapp · 1986
11993–1993
Landers v. State green
texcrimapp · 1974
11990–1990
Wallace v. State green
texcrimapp · 1983
11990–1990
McKay v. State green
texcrimapp · 1985
11990–1990
Ramirez v. State green
texcrimapp · 1976
11987–1987
Miller v. California green
scotus · 1973
11983–1983
Landreth v. Reed green
texapp · 1978
11979–1979
City of Amarillo v. Amarillo Lodge No. 731, AF & AM green
tex · 1972
11974–1974

Statutes the citing opinions construe

TX § Tex. Penal Code § 12.32 (16) TX § Tex. Penal Code § 12.33 (14) TX § Tex. Penal Code § 12.34 (12) TX § Tex. Penal Code § 12.42 (8) TX § Tex. Penal Code § 12.35 (6) TX § Tex. Penal Code § 22.021 (4) TX § Tex. Penal Code § 22.011 (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

CT 114 (1981–2025) TX 80 (1974–2024) PA 64 (1975–2025) OH 47 (1991–2026) WA 33 (2003–2024) ID 30 (1996–2020) MT 26 (1973–2020) MD 22 (1990–2022) IN 20 (1983–2017) MS 20 (1987–2022) LA 19 (1976–2015) NJ 19 (1978–2020) MO 16 (1979–2025) FL 15 (1982–2023) MI 14 (1990–2025) CA 13 (1975–2023) AZ 12 (1982–2023) VA 9 (1986–2025) TN 9 (1994–2024) NC 8 (1992–2024) DE 8 (1984–2025) CO 8 (1983–2025) OK 8 (1985–2013) IL 7 (1998–2021) SD 6 (1992–2006) HI 5 (2008–2013) DC 5 (1980–2024) MN 5 (1985–2015) OR 4 (1983–2022) NM 4 (2000–2025) WI 4 (1980–2023) IA 4 (1976–2020) KY 4 (1993–2025) NY 4 (1999–2008) SC 4 (1997–2024) GA 4 (1995–2025) WY 4 (2005–2016) ME 3 (1995–2012) NE 3 (2013–2022) RI 2 (1995–2005) UT 2 (2010–2025) WV 2 (1989–2003) MA 2 (1999–2020)

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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