interspousal tort immunity (Texas) · Go Syfert
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interspousal tort immunity in Texas

11 Texas opinions name it 2 courts 1972–2023 1 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 (8)

CaseFollowedCited
Bounds v. Caudlegreen
tex · 1977 · cited in 4 Texas opinions naming this issue, 1979–1993
2 sentences

1993Their criticisms would seem to be better directed at the court’s earlier decisions to abrogate the doctrine of interspousal tort immunity in Bounds v. Caudle, 560 S.W.2d 925 (Tex.1977), and Price v. Price, 732 S.W.2d 316 (Tex.1987). .

1993Their criticisms would seem to be better directed at the court’s earlier decisions to abrogate the doctrine of interspousal tort immunity in Bounds v. Caudle, 560 S.W.2d 925 (Tex.1977), and Price v. Price, 732 S.W.2d 316 (Tex.1987). .

24
Price v. Pricegreen
tex · 1987 · cited in 3 Texas opinions naming this issue, 1993–2023
2 sentences

2023See, e.g., Price v. Price, 732 S.W.2d 316, 319 (Tex. 1987) (abolishing the common- law doctrine of interspousal tort immunity); Rogers v. Tennessee, 532 U.S. 451 , 453–55 (2001) (describing the consequences of the Tennessee Supreme Court’s abolition of the old common-law “year and a day rule,” under which a defendant could not be convicted of murder if the victim survived longer than that period of time). 5 The question is not of authority but of propriety.

1993Their criticisms would seem to be better directed at the court’s earlier decisions to abrogate the doctrine of interspousal tort immunity in Bounds v. Caudle, 560 S.W.2d 925 (Tex.1977), and Price v. Price, 732 S.W.2d 316 (Tex.1987). .

23
Nickerson v. Nickersongreen
tex · 1886 · cited in 4 Texas opinions naming this issue, 1972–2015
2 sentences

1979In his single point of error, appellant asserts that the interspousal tort immunity doctrine “is no longer a viable concept in view of recent case law and legislative enactments which have abrogated any and all policies supporting said doctrine.” The doctrine of interspousal tort immunity was adopted in Texas in the case of Nickerson and Matson v. Nickerson, 65 Tex. 281 (1886).

1977The doctrine of interspousal tort immunity was adopted in Texas in the case of Nickerson and Matson v. Nickerson, 65 Tex. 281 (1886), and was last considered and upheld by this Court in Turner v. Turner, 385 S.W.2d 230 (Tex.1965).

14
Abbott v. Abbottgreen
me · 1877 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015See Nickerson v. Nickerson, 65 Tex. 281, 283 (1886) (tort inflicted on wife by her husband “gave no right of action to the wife against the husband,” “no compensation could be given to the wife, through a civil action”), overruled by Price v. Price, 732 S.W.2d 316 , 316–19 (Tex. 1987) (abolishing interspousal tort immunity doctrine); see also Abbott v. Abbott, 67 Me. 304 , 306–07 (1877) (“So to speak, marriage acts as a perpetually operating discharge of all wrongs between man and wife, committed by one upon the other.”); Peters v. Peters, 42 Iowa 182, 183 (1875) (changes in relation of husban

2015See Nickerson v. Nickerson, 65 Tex. 281, 283 (1886) (tort inflicted on wife by her husband “gave no right of action to the wife against the husband,” “no compensation could be given to the wife, through a civil action”), overruled by Price v. Price, 732 S.W.2d 316 , 316–19 (Tex. 1987) (abolishing interspousal tort immunity doctrine); see also Abbott v. Abbott, 67 Me. 304 , 306–07 (1877) (“So to speak, marriage acts as a perpetually operating discharge of all wrongs between man and wife, committed by one upon the other.”); Peters v. Peters, 42 Iowa 182, 183 (1875) (changes in relation of husban

11
Peters v. Petersgreen
iowa · 1875 · cited in 1 Texas opinions naming this issue, 2015–2015
2 sentences

2015See Nickerson v. Nickerson, 65 Tex. 281, 283 (1886) (tort inflicted on wife by her husband “gave no right of action to the wife against the husband,” “no compensation could be given to the wife, through a civil action”), overruled by Price v. Price, 732 S.W.2d 316 , 316–19 (Tex. 1987) (abolishing interspousal tort immunity doctrine); see also Abbott v. Abbott, 67 Me. 304 , 306–07 (1877) (“So to speak, marriage acts as a perpetually operating discharge of all wrongs between man and wife, committed by one upon the other.”); Peters v. Peters, 42 Iowa 182, 183 (1875) (changes in relation of husban

2015See Nickerson v. Nickerson, 65 Tex. 281, 283 (1886) (tort inflicted on wife by her husband “gave no right of action to the wife against the husband,” “no compensation could be given to the wife, through a civil action”), overruled by Price v. Price, 732 S.W.2d 316 , 316–19 (Tex. 1987) (abolishing interspousal tort immunity doctrine); see also Abbott v. Abbott, 67 Me. 304 , 306–07 (1877) (“So to speak, marriage acts as a perpetually operating discharge of all wrongs between man and wife, committed by one upon the other.”); Peters v. Peters, 42 Iowa 182, 183 (1875) (changes in relation of husban

11
Chiles v. Chilesgreen
texapp · 1989 · cited in 1 Texas opinions naming this issue, 1993–1993
2 sentences

1993See 855 S.W.2d at 627 (Phillips, C.J., dissenting). [15] We necessarily disapprove of the contrary holding in Chiles v. Chiles, 779 S.W.2d 127 (Tex. App.—Houston [14th Dist.] 1989, writ denied) (declining to recognize intentional infliction of emotional distress as a separate cause of action in a divorce suit). [16] A [divorce action] plaintiff ... may join as independent claims any or as many claims either legal or equitable or both as he may have against the opposing party....

1993See 855 S.W.2d at 627 (Phillips, C.J., dissenting). [15] We necessarily disapprove of the contrary holding in Chiles v. Chiles, 779 S.W.2d 127 (Tex. App.—Houston [14th Dist.] 1989, writ denied) (declining to recognize intentional infliction of emotional distress as a separate cause of action in a divorce suit). [16] A [divorce action] plaintiff ... may join as independent claims any or as many claims either legal or equitable or both as he may have against the opposing party....

11
Hack v. Hackgreen
pa · 1981 · cited in 1 Texas opinions naming this issue, 1986–1986
2 sentences

1986While we may agree with this statement by the Pennsylvania Supreme Court in Hack v. Hack, 495 Pa. 300 , 433 A.2d 859, 860-61 (1981), “A tortfeasor’s immunity from liability because of his marital relationship with the injured party cannot be sustained on the basis of law, logic or public policy,” this court will refrain from ruling on the whole doctrine of interspousal tort immunity as it applies in Texas to negligent acts of a spouse when the cause of action accrues during the marriage relationship.

1986While we may agree with this statement by the Pennsylvania Supreme Court in Hack v. Hack, 495 Pa. 300 , 433 A.2d 859, 860-61 (1981), “A tortfeasor’s immunity from liability because of his marital relationship with the injured party cannot be sustained on the basis of law, logic or public policy,” this court will refrain from ruling on the whole doctrine of interspousal tort immunity as it applies in Texas to negligent acts of a spouse when the cause of action accrues during the marriage relationship.

11
Renfrow v. Gojohngreen
moctapp · 1980 · cited in 1 Texas opinions naming this issue, 1986–1986
2 sentences

1986At least 29 states have now abrogated the interspousal tort immunity doctrine, and several others have curtailed its application. [1] A comprehensive 1980 list is also contained in Renfrow v. Gojohn, 600 S.W.2d 77, 80-82 (Mo.App.1980).

1986At least 29 states have now abrogated the interspousal tort immunity doctrine, and several others have curtailed its application. 1 A comprehensive 1980 list is also contained in Renfrow v. Gojohn, 600 S.W.2d 77, 80-82 (Mo.App.1980).

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
Robertson v. Estate of McKnight green
tex · 1980
2 sentences

1984Robertson v. The Estate of McKnight, 591 S.W.2d 639 (Tex.Civ.App. — Tyler 1979), rev’d on other grounds, 609 S.W.2d 534 (Tex.1980).

1980Robertson v. Estate of McKnight, 591 S.W.2d 639 (Tex.Civ.App.—Tyler 1979), rev’d on other grounds, 609 S.W.2d 534 (Tex.1980); Bruno v. Bruno, 589 S.W.2d 179 (Tex.Civ.App.—Waco 1979, writ ref’d n.r.e.).

21980–1984
Robertson v. Estate of McKnight green
texapp · 1979
2 sentences

1984Robertson v. The Estate of McKnight, 591 S.W.2d 639 (Tex.Civ.App. — Tyler 1979), rev’d on other grounds, 609 S.W.2d 534 (Tex.1980).

1980Robertson v. Estate of McKnight, 591 S.W.2d 639 (Tex.Civ.App.—Tyler 1979), rev’d on other grounds, 609 S.W.2d 534 (Tex.1980); Bruno v. Bruno, 589 S.W.2d 179 (Tex.Civ.App.—Waco 1979, writ ref’d n.r.e.).

21980–1984
Turner v. Turner green
tex · 1964
2 sentences

1977The doctrine of interspousal tort immunity was adopted in Texas in the case of Nickerson and Matson v. Nickerson, 65 Tex. 281 (1886), and was last considered and upheld by this Court in Turner v. Turner, 385 S.W.2d 230 (Tex.1965).

1977The doctrine of interspousal tort immunity was adopted in Texas in the case of Nickerson and Matson v. Nickerson, 65 Tex. 281 (1886), and was last considered and upheld by this Court in Turner v. Turner, 385 S.W.2d 230 (Tex.1965).

21972–1977
Rogers v. Tennessee green
scotus · 2001
1 sentence

2023See, e.g., Price v. Price, 732 S.W.2d 316, 319 (Tex. 1987) (abolishing the common- law doctrine of interspousal tort immunity); Rogers v. Tennessee, 532 U.S. 451 , 453–55 (2001) (describing the consequences of the Tennessee Supreme Court’s abolition of the old common-law “year and a day rule,” under which a defendant could not be convicted of murder if the victim survived longer than that period of time). 5 The question is not of authority but of propriety.

12023–2023
Longendyke v. Longendyke green
· 1863
2 sentences

2015See Nickerson v. Nickerson, 65 Tex. 281, 283 (1886) (tort inflicted on wife by her husband “gave no right of action to the wife against the husband,” “no compensation could be given to the wife, through a civil action”), overruled by Price v. Price, 732 S.W.2d 316 , 316–19 (Tex. 1987) (abolishing interspousal tort immunity doctrine); see also Abbott v. Abbott, 67 Me. 304 , 306–07 (1877) (“So to speak, marriage acts as a perpetually operating discharge of all wrongs between man and wife, committed by one upon the other.”); Peters v. Peters, 42 Iowa 182, 183 (1875) (changes in relation of husban

2015See Nickerson v. Nickerson, 65 Tex. 281, 283 (1886) (tort inflicted on wife by her husband “gave no right of action to the wife against the husband,” “no compensation could be given to the wife, through a civil action”), overruled by Price v. Price, 732 S.W.2d 316 , 316–19 (Tex. 1987) (abolishing interspousal tort immunity doctrine); see also Abbott v. Abbott, 67 Me. 304 , 306–07 (1877) (“So to speak, marriage acts as a perpetually operating discharge of all wrongs between man and wife, committed by one upon the other.”); Peters v. Peters, 42 Iowa 182, 183 (1875) (changes in relation of husban

12015–2015
Speer & Goodnight v. Sykes green
· 1909
2 sentences

1986In Sykes v. Speer, 112 S.W. 422 (Tex.Civ.App.—1908), rev’d on other grounds, 102 Tex. 451 , 119 S.W. 86 (1909), the court wrote that a judgment awarding the wife damages for personal injuries was void on its face since it showed that the injuries complained of were committed during the marital relationship.

1986In Sykes v. Speer, 112 S.W. 422 (Tex.Civ.App.—1908), rev’d on other grounds, 102 Tex. 451 , 119 S.W. 86 (1909), the court wrote that a judgment awarding the wife damages for personal injuries was void on its face since it showed that the injuries complained of were committed during the marital relationship.

11986–1986
Mogford v. Mogford green
texapp · 1981
2 sentences

1983Appellant concedes that recovery for personal injuries arising out of willful and intentional torts committed by one spouse upon the other during marriage is no longer barred by the doctrine of interspousal tort immunity, Mogford v. Mogford, 616 S.W.2d 936 (Tex.Civ.App. — San Antonio 1981, writ ref’d, n.r.e.).

1983Appellant concedes that recovery for personal injuries arising out of willful and intentional torts committed by one spouse upon the other during marriage is no longer barred by the doctrine of interspousal tort immunity, Mogford v. Mogford, 616 S.W.2d 936 (Tex.Civ.App. — San Antonio 1981, writ ref’d, n.r.e.).

11983–1983
Bruno v. Bruno green
texapp · 1979
2 sentences

1980Robertson v. Estate of McKnight, 591 S.W.2d 639 (Tex.Civ.App.—Tyler 1979), rev’d on other grounds, 609 S.W.2d 534 (Tex.1980); Bruno v. Bruno, 589 S.W.2d 179 (Tex.Civ.App.—Waco 1979, writ ref’d n.r.e.).

1980Robertson v. Estate of McKnight, 591 S.W.2d 639 (Tex.Civ.App.—Tyler 1979), rev’d on other grounds, 609 S.W.2d 534 (Tex.1980); Bruno v. Bruno, 589 S.W.2d 179 (Tex.Civ.App.—Waco 1979, writ ref’d n.r.e.).

11980–1980
McGlothlin v. McGlothlin green
texapp · 1972
1 sentence

1972This is true regardless whether the tort was negligent or intentional Nickerson and Matson v. Nickerson, supra; Turner v. Turner, 385 S.W.2d 230 (Tex.1965); Lunt v. Lunt, 121 S.W.2d 445 (Tex.Civ.App.1938, writ ref.); McGlothlin v. McGlothlin, 476 S.W.2d 333 (Tex.Civ.App.1972, writ ref. n. r. e.); Comment: Intra Family Immunity — The Doctrine and Its Present Status, 20 Baylor L.Rev. 27 (Winter 1968).

11972–1972
Lunt v. Lunt neutral
· 1938
1 sentence

1972This is true regardless whether the tort was negligent or intentional Nickerson and Matson v. Nickerson, supra; Turner v. Turner, 385 S.W.2d 230 (Tex.1965); Lunt v. Lunt, 121 S.W.2d 445 (Tex.Civ.App.1938, writ ref.); McGlothlin v. McGlothlin, 476 S.W.2d 333 (Tex.Civ.App.1972, writ ref. n. r. e.); Comment: Intra Family Immunity — The Doctrine and Its Present Status, 20 Baylor L.Rev. 27 (Winter 1968).

11972–1972

Where else courts name it

GA 17 (1981–2024) FL 16 (1979–2018) TX 11 (1972–2023) AZ 9 (1971–1994) MD 6 (1978–2022) IL 5 (1981–1989) WA 4 (1972–1986) NE 4 (1979–2002) MA 3 (1980–1987) MI 3 (1965–1970) NV 3 (1974–1985) NJ 3 (1981–1995) MO 2 (1979–1986) KS 2 (1983–1987) MT 2 (1986–1986) OH 2 (1983–1989) TN 2 (1987–1997) CT 2 (1993–1994) UT 2 (1983–1987)

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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