parens patriae doctrine (Texas) · Go Syfert
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parens patriae doctrine in Texas

9 Texas opinions name it 1 courts 1946–2024 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 (6)

CaseFollowedCited
Farmers Group, Inc. v. Lubingreen
tex · 2007 · cited in 2 Texas opinions naming this issue, 2024–2024
2 sentences

2024See KC Greenhouse, 445 S.W.3d at 175 (citing Farmers Group, Inc. v. Lubin, 222 S.W.3d 417, 423 (Tex. 2007)).

2024See In re KC Greenhouse Patio Apartments, LP, 445 S.W.3d 168, 175 (Tex. App.— Houston [1st Dist] 2012) (orig. proceeding) (citing Farmers Grp., Inc. v. Lubin, 222 S.W.3d 417, 423 (Tex. 2007)).

22
in Re KC Greenhouse Patio Apartments. LPgreen
texapp · 2012 · cited in 2 Texas opinions naming this issue, 2024–2024
2 sentences

2024See KC Greenhouse, 445 S.W.3d at 175 (citing Farmers Group, Inc. v. Lubin, 222 S.W.3d 417, 423 (Tex. 2007)).

2024See In re KC Greenhouse Patio Apartments, LP, 445 S.W.3d 168, 175 (Tex. App.— Houston [1st Dist] 2012) (orig. proceeding) (citing Farmers Grp., Inc. v. Lubin, 222 S.W.3d 417, 423 (Tex. 2007)).

22
Board of County Commissioners v. Denver Board of Water Commissionersgreen
colo · 1986 · cited in 2 Texas opinions naming this issue, 2010–2010
2 sentences

2010Comm’rs v. Denver Bd. of Water Comm’rs, 718 P.2d 235, 241 (Colo.1986) (holding that counties lack the element of sovereignty necessary for parens patriae standing because “counties, unlike states, are not independent governmental entities existing by reason of any inherent sovereign authority of their residents”).

2010Comm’rs v. Denver Bd. of Water Comm’rs, 718 P.2d 235, 241 (Colo. 1986) (holding that counties lack the element of sovereignty necessary for parens patriae standing because “counties, unlike states, are not independent governmental entities existing by reason of any inherent sovereign authority of their residents”). -6- 04-10-00478-CV Moreover, even if the doctrine of parens patriae did apply to counties, the doctrine has been used “sparingly” in Texas.

22
Lakeshore Utility Co. v. Texas Natural Resource Conservation Commissiongreen
texapp · 2002 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010Conservation Comm’n, 92 S.W.3d 556, 565 (Tex. App.—Austin 2002) (explaining that under the doctrine of parens patriae, “the State, as ‘parent of the country,’ may sue to protect an interest in the health and well-being – both physical and economic – of its residents in general”), rev’d in part on other grounds, 164 S.W.3d 368 (Tex. 2005); Bachynsky v. State, 747 S.W.2d 868, 869 (Tex. App.—Dallas 1988, writ denied) (same).

11
Bachynsky v. Stategreen
texapp · 1988 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010Conservation Comm’n, 92 S.W.3d 556, 565 (Tex. App.—Austin 2002) (explaining that under the doctrine of parens patriae, “the State, as ‘parent of the country,’ may sue to protect an interest in the health and well-being – both physical and economic – of its residents in general”), rev’d in part on other grounds, 164 S.W.3d 368 (Tex. 2005); Bachynsky v. State, 747 S.W.2d 868, 869 (Tex. App.—Dallas 1988, writ denied) (same).

11
Colyar v. THIRD JUDICIAL DIST. COURT, ETC.green
utd · 1979 · cited in 1 Texas opinions naming this issue, 1985–1985
1 sentence

1985We agree with this declaration in Colyar v. Third Judicial District Court for Salt Lake County, 469 F.Supp. 424, 430 (D.Utah 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 (4)

CaseCitedYears
Hawaii v. Standard Oil Co. of Cal. green
scotus · 1972
2 sentences

2005In the United States, the parens patriae doctrine expanded to include state-brought suits to “prevent or repair harm to its quasi-sovereign interests.” Hawaii, 405 U.S. at 257-58 , 92 S.Ct. 885 .

2005In the United States, the parens patriae doctrine expanded to include state-brought suits to “prevent or repair harm to its quasi-sovereign interests.” Hawaii, 405 U.S. at 257-58 , 92 S.Ct. 885 .

32005–2005
Texas Natural Resource Conservation Commission v. Lakeshore Utility Company, Inc., Sentry Title Company, Inc., Alan D. Whatley, and Thelma J. Whatley green
tex · 2005
1 sentence

2010Conservation Comm’n, 92 S.W.3d 556, 565 (Tex. App.—Austin 2002) (explaining that under the doctrine of parens patriae, “the State, as ‘parent of the country,’ may sue to protect an interest in the health and well-being – both physical and economic – of its residents in general”), rev’d in part on other grounds, 164 S.W.3d 368 (Tex. 2005); Bachynsky v. State, 747 S.W.2d 868, 869 (Tex. App.—Dallas 1988, writ denied) (same).

12010–2010
Neely v. Brogden green
texcommnapp · 1922
1 sentence

1946Not only so, but in doing that, when this court looks — as is its bounden duty in construing her will — “ ‘beyond mere gramatical form [of it], to * * * the internal evidence of [its maker’s intentions’ Neely v. Brogden, Tex.Civ.App., 239 S.W. 192 , 194”, it as an entirety falls clearly within the principles declared by our Supreme Court in its most recent declaration of the rules of law in Texas governing the construction and application of public and charity trusts — to-wit, Powers v. First National Bank of Corsicana, 138 Tex. 604 , 161 S.W.2d 273, 283 , supra. That deliverance — to say noth

11946–1946
Powers v. First Natl. Bank of Corsicana green
· 1942
2 sentences

1946Not only so, but in doing that, when this court looks — as is its bounden duty in construing her will — “ ‘beyond mere gramatical form [of it], to * * * the internal evidence of [its maker’s intentions’ Neely v. Brogden, Tex.Civ.App., 239 S.W. 192 , 194”, it as an entirety falls clearly within the principles declared by our Supreme Court in its most recent declaration of the rules of law in Texas governing the construction and application of public and charity trusts — to-wit, Powers v. First National Bank of Corsicana, 138 Tex. 604 , 161 S.W.2d 273, 283 , supra. That deliverance — to say noth

1946Not only so, but in doing that, when this court looks — as is its bounden duty in construing her will — “ ‘beyond mere gramatical form [of it], to * * * the internal evidence of [its maker’s intentions’ Neely v. Brogden, Tex.Civ.App., 239 S.W. 192 , 194”, it as an entirety falls clearly within the principles declared by our Supreme Court in its most recent declaration of the rules of law in Texas governing the construction and application of public and charity trusts — to-wit, Powers v. First National Bank of Corsicana, 138 Tex. 604 , 161 S.W.2d 273, 283 , supra. That deliverance — to say noth

11946–1946

Statutes the citing opinions construe

TX § Tex. Ins. Code § 83.051 (3) USC § 15u.s.c.15c (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

NJ 34 (1953–2025) IL 26 (1978–2024) CA 23 (1964–2025) NY 16 (1968–2025) PA 16 (1964–2021) OH 13 (1988–2026) MD 13 (1984–2021) IN 10 (1979–2023) TX 9 (1946–2024) FL 8 (1977–2015) CO 8 (1970–2025) MT 7 (1962–2012) MN 7 (1987–2018) KS 7 (1977–2004) OK 7 (1963–2012) WV 6 (1963–2024) VT 6 (1983–2024) NE 6 (1968–2020) AK 5 (1976–2024) IA 4 (1985–2020) AZ 4 (1965–2022) MA 4 (1979–2014) WA 4 (2014–2015) SC 3 (1989–2017) LA 3 (1971–2008) TN 3 (1998–2014) CT 2 (1992–2000) GA 2 (1982–1995) MO 2 (1950–1988) VA 2 (1995–2003) NM 2 (1954–1990) DC 2 (1985–2018) WI 2 (1980–2006) AL 2 (1937–2008) MS 2 (1969–1982) NC 2 (1985–2000) VI 2 (1977–2014) MI 2 (1993–2008)

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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