alternate claim (Texas) · Go Syfert
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alternate claim in Texas

8 Texas opinions name it 2 courts 1996–2019 0 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 (5)

CaseFollowedCited
Creditwatch, Inc. v. Jacksongreen
tex · 2005 · cited in 2 Texas opinions naming this issue, 2008–2008
2 sentences

2008Hoffmann-La Roche, Inc., 144 S.W.3d at 448 ; see also Creditwatch, Inc., 157 S.W.3d at 817 (“As [the plaintiffs] complaints are covered by other statutory remedies, she cannot assert them as intentional infliction claims just because those avenues may now be barred.”); Louis v. Mobil Chem.

2008Hoffmann-La Roche, Inc., 144 S.W.3d at 448 ; see also Creditwatch, Inc., 157 S.W.3d at 817 (“As [the plaintiff’s] complaints are covered by other statutory remedies, she cannot assert them as intentional infliction claims just because those avenues may now be barred.”); Louis v. Mobil Chem.

22
Draker v. Schreibergreen
texapp · 2008 · cited in 2 Texas opinions naming this issue, 2011–2019
2 sentences

2019Because this tort was never intended to provide plaintiffs an easier and broader way to allege claims that are already addressed by our existing civil and criminal laws, nor was it intended to replace or duplicate existing statutory or 45 common law remedies, if the gravamen of a plaintiff’s complaint is another tort, “a claim for [IIED] will not lie regardless of whether the plaintiff succeeds on, or even makes the alternate claim.” Draker v. Schreiber, 271 S.W.3d 318, 322 (Tex. App.—San Antonio 2008, no pet.).

2011“Thus, if the gravamen of a plaintiffs complaint is another tort, a claim for intentional infliction of emotional distress claim will not lie regardless of whether the plaintiff succeeds on, or even makes the alternate claim.” Draker, 271 S.W.3d at 322 .

12
Howell v. Estesgreen
tex · 1888 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014Id. at 63.

11
Crown Life Insurance Company v. Casteelgreen
tex · 2000 · cited in 1 Texas opinions naming this issue, 2001–2001
1 sentence

2001Instead, the court applied the alternate standard, that the error "probably prevented the [appealing party] from properly presenting the case.” See Cas- *333 teel, 22 S.W.3d at 388 (supreme court opinion) (quoting from Tex.R.App.P. 61.1(a)(2) (reversible error standard for supreme court)); see also Tex.R.App.P. 44.1(a)(2) (reversible error standard for court of appeals).

11
State v. Richardsgreen
tex · 1957 · cited in 1 Texas opinions naming this issue, 1996–1996
2 sentences

1996State v. Richards, 157 Tex. 166 , 301 S.W.2d 597, 602 (1957).

1996State v. Richards, 157 Tex. 166 , 301 S.W.2d 597, 602 (1957).

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 (2)

CaseCitedYears
Hoffmann-La Roche Inc. v. Zeltwanger green
tex · 2004
2 sentences

2008Hoffmann-La Roche, Inc., 144 S.W.3d at 448 ; see also Creditwatch, Inc., 157 S.W.3d at 817 (“As [the plaintiffs] complaints are covered by other statutory remedies, she cannot assert them as intentional infliction claims just because those avenues may now be barred.”); Louis v. Mobil Chem.

2008Hoffmann-La Roche, Inc., 144 S.W.3d at 448 ; see also Creditwatch, Inc., 157 S.W.3d at 817 (“As [the plaintiff’s] complaints are covered by other statutory remedies, she cannot assert them as intentional infliction claims just because those avenues may now be barred.”); Louis v. Mobil Chem.

22008–2008
Ex Parte Walker green
texcrimapp · 1990
1 sentence

2019Walker, 794 S.W.2d at 37 .

12019–2019

Where else courts name it

CA 37 (1958–2026) IL 14 (1981–2025) WA 12 (1957–2017) WI 12 (1992–2025) TX 8 (1996–2019) CO 7 (1996–2025) OH 7 (2000–2024) CT 7 (1980–2008) LA 6 (1955–1998) MI 6 (1974–2025) PA 6 (1995–2025) MD 6 (1975–2017) GA 6 (1985–2020) FL 5 (1984–2018) NE 5 (1981–2019) WV 4 (2006–2026) NY 4 (1994–2015) NM 4 (2011–2025) SD 3 (1997–2022) WY 3 (1985–2001) MA 3 (2007–2025) NJ 3 (2007–2012) VI 3 (2011–2015) AL 3 (2008–2024) AR 3 (1983–2013) MT 3 (2007–2025) ND 2 (1988–2013) MO 2 (1983–2019) ID 2 (1993–2020) AZ 2 (1998–2025) IN 2 (1988–2009) VA 2 (1994–2002) UT 2 (2018–2024)

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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