subject matter jurisdiction challenge (Texas) · Go Syfert
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subject matter jurisdiction challenge in Texas

10 Texas opinions name it 2 courts 2008–2024 2 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 (11)

CaseFollowedCited
Texas Ass'n of Business v. Texas Air Control Boardgreen
tex · 1993 · cited in 3 Texas opinions naming this issue, 2008–2012
2 sentences

2012But it can be raised only before a court with competent jurisdiction.”40 Thus, even though a subject-matter-jurisdiction challenge remains viable, we may not decide such a challenge unless it is properly before us.41 38 E.g., Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 445 (Tex. 1993); see also Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 . 39 See Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 ; see also Siddiqui v. Unlimited Asset Recovery, Inc., No. 01-09-00026-CV, 2009 WL 3930748 , at *2 (Tex. App.—Houston [1st Dist.] Nov. 19, 2009, no pet.) (mem. op.) (“While

2008Texas Ass’n of Bus. v. Texas Air Control Bd., 852 S.W.2d 440, 445-46 (Tex. 1993). 2.

33
Texas Department of Parks & Wildlife v. Mirandagreen
tex · 2004 · cited in 3 Texas opinions naming this issue, 2012–2024
2 sentences

2024See Miranda, 133 S.W.3d at 226 .

2014See Kirwan, 298 S.W.3d at 622 ; Miranda, 133 S.W.3d at 228 .

13
In Re SJAgreen
texapp · 2008 · cited in 1 Texas opinions naming this issue, 2022–2022
1 sentence

2022See In re S.J.A., 272 S.W.3d 678, 682 (Tex. App.—Dallas 2008, no pet.).

11
City of El Paso, Mayor Oscar Leeser, City Representatives Emma Acosta, Carl L. Robinson, Michiel R. Noe, Courtney C. Niland, Ann Morgan Lilly, Larry Romero, Claudia Ordaz and Lily Limon v. Waterblasting Technologies, Inc. and Thomas G. Wicker, Jr.green
texapp · 2016 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020See City of El Paso v. Waterblasting Technologies, Inc., 491 S.W.3d 890, 903-04 (Tex.App.—El Paso 2016, no pet.).

11
Sledge, Ex Parte Casey Tyronegreen
texcrimapp · 2013 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015See Ex Parte Sledge, 391 S.W.3d 104, 108 (Tex. Crim.

11
Moss, Jecia Javettegreen
texcrimapp · 2014 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015App. 2009) 10 – Appellant’s Response to State’s Petition for Discretionary Review However, this assumption appears to have been resolved in Murray itself and this Court’s recent unanimous decision in Ex parte Moss, 446 S.W.3d 786, 788-89 (Tex. Crim.

11
City of Waco v. Kirwangreen
tex · 2009 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See Kirwan, 298 S.W.3d at 622 ; Miranda, 133 S.W.3d at 228 .

11
Brenham Housing Authority v. Daviesgreen
texapp · 2005 · cited in 1 Texas opinions naming this issue, 2012–2012
2 sentences

2012But it can be raised only before a court with competent jurisdiction.”40 Thus, even though a subject-matter-jurisdiction challenge remains viable, we may not decide such a challenge unless it is properly before us.41 38 E.g., Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 445 (Tex. 1993); see also Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 . 39 See Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 ; see also Siddiqui v. Unlimited Asset Recovery, Inc., No. 01-09-00026-CV, 2009 WL 3930748 , at *2 (Tex. App.—Houston [1st Dist.] Nov. 19, 2009, no pet.) (mem. op.) (“While

2012But it can be raised only before a court with competent jurisdiction.”40 Thus, even though a subject-matter-jurisdiction challenge remains viable, we may not decide such a challenge unless it is properly before us.41 38 E.g., Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 445 (Tex. 1993); see also Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 . 39 See Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 ; see also Siddiqui v. Unlimited Asset Recovery, Inc., No. 01-09-00026-CV, 2009 WL 3930748 , at *2 (Tex. App.—Houston [1st Dist.] Nov. 19, 2009, no pet.) (mem. op.) (“While

11
Lehmann v. Har-Con Corp.red
tex · 2001 · cited in 1 Texas opinions naming this issue, 2012–2012
1 sentence

2012While a party generally will not have the opportunity to engage in additional discovery, amend pleadings, or introduce new evidence in response to a subject-matter-jurisdiction challenge raised for the first time on appeal from a final judgment, a final judgment connotes an opportunity to fully developed the record on all issues necessary to resolution of the entire case;60 an interlocutory order does not. 60 See, e.g., Lehmann v. Har-Con Corp., 39 S.W.3d 191, 200 (Tex. 2001) (observing that final judgment is proper only if it disposes of all parties and claims and that summary judgment orders

11
Mitchell v. Forsythgreen
scotus · 1985 · cited in 1 Texas opinions naming this issue, 2012–2012
2 sentences

2012While a party generally will not have the opportunity to engage in additional discovery, amend pleadings, or introduce new evidence in response to a subject-matter-jurisdiction challenge raised for the first time on appeal from a final judgment, a final judgment connotes an opportunity to fully developed the record on all issues necessary to resolution of the entire case;60 an interlocutory order does not. 60 See, e.g., Lehmann v. Har-Con Corp., 39 S.W.3d 191, 200 (Tex. 2001) (observing that final judgment is proper only if it disposes of all parties and claims and that summary judgment orders

2012While a party generally will not have the opportunity to engage in additional discovery, amend pleadings, or introduce new evidence in response to a subject-matter-jurisdiction challenge raised for the first time on appeal from a final judgment, a final judgment connotes an opportunity to fully developed the record on all issues necessary to resolution of the entire case;60 an interlocutory order does not. 60 See, e.g., Lehmann v. Har-Con Corp., 39 S.W.3d 191, 200 (Tex. 2001) (observing that final judgment is proper only if it disposes of all parties and claims and that summary judgment orders

11
Thomas v. Longgreen
tex · 2006 · cited in 1 Texas opinions naming this issue, 2011–2011
1 sentence

2011In Thomas v. Long, the Supreme Court of Texas held a trial court should address subject-matter jurisdiction claim-by-claim, dismissing claims over which it lacks subject-matter jurisdiction and retaining claims in the same case over which it has jurisdiction. 207 S.W.3d 334, 338-39 (Tex.2006).

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
Rhodes v. State green
texcrimapp · 2007
2 sentences

2015We assume, without deciding, that the State is not barred by a subject matter jurisdiction claim.” Id. at 882 . 2 302 S.W.3d 874 (Tex. Crim.

2015See Murray,302 S.W.3d at 882 n.42 (enrphasis added); Rhodes, 240 S.W.3d at 891 ; see also Derosier,2015 Tex. App.LEXIS I I155, at*5,14. 6 The Murray opinion assumed the State was not barred from advancing estoppel in a subject-matter jurisdiction claim.

22015–2015
Murray, Raymond Desmond green
texcrimapp · 2009
1 sentence

2015We assume, without deciding, that the State is not barred by a subject matter jurisdiction claim.” Id. at 882 . 2 302 S.W.3d 874 (Tex. Crim.

12015–2015
Marin v. State green
texcrimapp · 1993
1 sentence

2015Furthermore, this Court’s solution begs the question, if this Court would not carve out a subject-matter jurisdiction exception for public policy then how could this 11 – Appellant’s Response to State’s Petition for Discretionary Review Court create an estoppel exception when subject-matter jurisdiction is an “absolute systemic requirement[-] * * * and [is] not forfeitable?” Marin v. State, 851 SW2d 275 (Tex.Crim.App.1993.) Subject-matter jurisdiction is “independent of the litigant’s wishes.

12015–2015
Waco Independent School District v. Gibson green
tex · 2000
1 sentence

2012F. The Texas Supreme Court has declined to resolve the split in the courts of appeals The Texas Supreme Court recently had an opportunity to resolve the split in the courts of appeals over this issue, but declined to reach it.57 Since then, the Texas Supreme Court has, on at least two occasions, exercised interlocutory jurisdiction over a subject-matter jurisdiction challenge on which the trial court had not had an opportunity to rule.58 In both cases, the Court did not address, and the parties did not challenge, the Texas Supreme Court’s jurisdiction to consider the new challenge to the trial

12012–2012
Austin Independent School District v. Lowery green
texapp · 2006
2 sentences

2012But it can be raised only before a court with competent jurisdiction.”40 Thus, even though a subject-matter-jurisdiction challenge remains viable, we may not decide such a challenge unless it is properly before us.41 38 E.g., Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 445 (Tex. 1993); see also Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 . 39 See Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 ; see also Siddiqui v. Unlimited Asset Recovery, Inc., No. 01-09-00026-CV, 2009 WL 3930748 , at *2 (Tex. App.—Houston [1st Dist.] Nov. 19, 2009, no pet.) (mem. op.) (“While

2012But it can be raised only before a court with competent jurisdiction.”40 Thus, even though a subject-matter-jurisdiction challenge remains viable, we may not decide such a challenge unless it is properly before us.41 38 E.g., Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 445 (Tex. 1993); see also Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 . 39 See Davies, 158 S.W.3d at 61 ; Lowery, 212 S.W.3d at 834 ; see also Siddiqui v. Unlimited Asset Recovery, Inc., No. 01-09-00026-CV, 2009 WL 3930748 , at *2 (Tex. App.—Houston [1st Dist.] Nov. 19, 2009, no pet.) (mem. op.) (“While

12012–2012

Where else courts name it

CT 65 (1997–2025) MS 11 (1992–2023) TX 10 (2008–2024) PA 9 (1990–2023) MO 5 (2004–2022) MI 4 (2018–2026) NY 4 (1993–2023) FL 4 (2020–2026) MN 4 (1997–2025) WA 4 (2020–2025) KS 3 (2019–2024) NC 3 (1981–2025) AL 3 (2013–2018) SC 3 (1998–2012) CO 3 (1999–2026) DE 2 (2019–2023) IA 2 (2016–2019) AK 2 (2013–2022) RI 2 (2004–2011) AZ 2 (2013–2016)

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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