deferred accrual exception in Texas

2015See La Gloria Oil and Gas Co., 84 S.W.3d 228, 233, n. 4 (Tex.App.-Tyler 2001), citing Rodessa Resources, Inc. v. Arcadia Exploration and Production Co., 5 S.W.3d 363, 366 (Tex.App.-Texarkana 1999, no pet.); S.V., 933 S.W.2d at 6 . 3.

2002See La Gloria Oil and Gas Co., 12-00-00032-CV, 2001 WL 1654936 n 4 (Tex. App.-Tyler December 21, 2001), citing Rodessa Resources, Inc. v. Arcadia Exploration and Production Co. , 5 S.W.3d 363, 366 (Tex. App.-Texarkana 1999, no pet.); S.V. , 933 S.W.2d at 6 . 3.

2015See La Gloria Oil and Gas Co., 84 S.W.3d 228, 233, n. 4 (Tex.App.-Tyler 2001), citing Rodessa Resources, Inc. v. Arcadia Exploration and Production Co., 5 S.W.3d 363, 366 (Tex.App.-Texarkana 1999, no pet.); S.V., 933 S.W.2d at 6 . 3.

2002See La Gloria Oil and Gas Co., 12-00-00032-CV, 2001 WL 1654936 n 4 (Tex. App.-Tyler December 21, 2001), citing Rodessa Resources, Inc. v. Arcadia Exploration and Production Co. , 5 S.W.3d 363, 366 (Tex. App.-Texarkana 1999, no pet.); S.V. , 933 S.W.2d at 6 . 3.

2001While some other Courts of Appeals have held that a separate trial on limitations is appropriate, see, e.g., Phipps v. Miller , 597 S.W.2d 458, 460 (Tex. Civ.

2001While some other Courts of Appeals have held that a separate trial on limitations is appropriate, see, e.g., Phipps v. Miller , 597 S.W.2d 458, 460 (Tex. Civ.

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer’s expertise and client’s ignorance of the law make wrong undiseovera-ble); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child bom with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiffs rectal nerves and muscles, causing loss of bowel control; hel

1996See Willis, 760 S.W.2d at 646 (attorney malpractice in drafting divorce decree led to forced partition of home; held discovery rule applies when lawyer's expertise and client's ignorance of the law make wrong undiscoverable); Nelson v. Krusen, 678 S.W.2d 918, 923 (Tex.1984) (child born with muscular dystrophy after doctor informed parents that mother did not carry muscular dystrophy gene; held statute precluding discovery rule was unconstitutional); Weaver, 561 S.W.2d at 794 (negligently performed hemorrhoidectomy damaged plaintiff's rectal nerves and muscles, causing loss of bowel control; he

1996Mercer, Inc., 769 S.W.2d 515, 518 (Tex.1988). *5 We have considered the applicability of the deferred accrual exception to the legal injury rule in an assortment of settings.