harsh rule (Texas) · Go Syfert
← Texas issues

harsh rule in Texas

58 Texas opinions name it 3 courts 1889–2018 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 (22)

CaseFollowedCited
Pelham v. Stategreen
texcrimapp · 1957 · cited in 7 Texas opinions naming this issue, 1972–1995
2 sentences

1992In that case, the chemist had testified that it was thought that the cocaine was no “more than %8,ooo of an ounce and maybe as little as l/w,m of an ounce.” Appreciating the extremely small quantity that was involved, the Court of Criminal Appeals referred to the decision of Pelham v. State, and wrote that “it would be a harsh rule, indeed, that would charge appellant with knowing possessing that which it required a microscope to identify.” Id. at 835 .

1987A similar holding was made in Coleman v. State, 545 S.W.2d 831, 835 (Tex.Crim.App.1977), where the amount of cocaine found was “no more than 5/28,ooo of an ounce and maybe as little as y28,ooo of an ounce.” Coleman cited Pelham v. State, 164 Tex.Crim. 226 , 298 S.W.2d 171 (1957), in which the court held that the amount of marihuana found in scrapings from the defendant’s pocket was insufficient to support a conviction because it was not a usable amount, and added: “It would be a harsh rule, indeed, that would charge appellant with knowingly possessing that which it required a microscope to ide

27
Coleman v. Stategreen
texcrimapp · 1977 · cited in 4 Texas opinions naming this issue, 1987–2006
2 sentences

2006As he points out, in Coleman v. State, 545 S.W.2d 831, 835 (Tex.Crim.App.1977), the Texas Court of Criminal Appeals stated unambiguously, and quite reasonably, “It would be a harsh rule, indeed, that would charge appellant with knowingly possessing that which it required a microscope to identify.” However, that court has also held there is no requirement that a controlled substance must be visible and measurable to support a conviction for possession of contraband.

1987A similar holding was made in Coleman v. State, 545 S.W.2d 831, 835 (Tex.Crim.App.1977), where the amount of cocaine found was “no more than 5/28,ooo of an ounce and maybe as little as y28,ooo of an ounce.” Coleman cited Pelham v. State, 164 Tex.Crim. 226 , 298 S.W.2d 171 (1957), in which the court held that the amount of marihuana found in scrapings from the defendant’s pocket was insufficient to support a conviction because it was not a usable amount, and added: “It would be a harsh rule, indeed, that would charge appellant with knowingly possessing that which it required a microscope to ide

24
Pension Committee of the University of Montreal Pension Plan v. Banc of America Securities, LLCred
nysd · 2010 · cited in 2 Texas opinions naming this issue, 2014–2015
2 sentences

2015Sec., 685 F. Supp. 2d 456, 470 (S.D.N.Y. 2010), abrogated on other grounds by Chin v. Port Auth. of N.Y. & N.J., 685 F.3d 135 (2d Cir. 2012) (″The least harsh instruction permits (but does not require) a jury to presume that the lost evidence is both relevant and favorable to the innocent party.″).

2014Sec., 685 F.Supp.2d 456, 470 (S.D.N.Y. 2010), abrogated on other grounds by Chin v. Port Auth. of N.Y. & N.J., 685 F.3d 135 (2d Cir.2012) ("The least harsh instruction permits (but does not require) a jury to presume that the lost evidence is both relevant and favorable to the innocent party.”). .

22
King v. Stategreen
texcrimapp · 1995 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006See King v. State , 895 S.W.2d 701, 702-04 (Tex. Crim.

2006See King v. State, 895 S.W.2d 701, 702-04 (Tex.Crim.App.1995); 1 see also Joseph v. State, 897 S.W.2d 374, 376 (Tex.Crim.App.1995) (finding it error to require controlled substance to be visible to naked eye to support conviction; visibility not an element of possession of controlled substance); Hyett v. State, 58 S.W.3d 826, 831 (Tex.App.-Houston [14th Dist.] 2001, pet ref'd).

22
Lowe v. Texas Tech Universitygreen
tex · 1976 · cited in 2 Texas opinions naming this issue, 2003–2003
2 sentences

2003See Lowe v. Texas Tech Univ ., 540 S.W.2d 297, 298 (Tex. 1976).

2003See Lowe v. Texas Tech Univ., 540 S.W.2d 297, 298 (Tex.1976).

22
Gilbert v. Fireside Enterprises, Inc.green
texapp · 1980 · cited in 2 Texas opinions naming this issue, 1981–1984
2 sentences

1984In Gilbert v. Fireside Enterprises, Inc., 611 S.W.2d 869, 879-80 (Tex.Civ.App.—Dallas 1980, no writ), we noted that res judicata is a harsh doctrine, which should be applied narrowly and with caution.

1984In Gilbert v. Fireside Enterprises, Inc., 611 S.W.2d 869, 879-80 (Tex.Civ.App. — Dallas 1980, no writ), we noted that res judicata is a harsh doctrine, which should be applied narrowly and with caution.

22
Chin v. Port Authority of New York & New Jerseygreen
ca2 · 2012 · cited in 2 Texas opinions naming this issue, 2014–2015
2 sentences

2015Sec., 685 F. Supp. 2d 456, 470 (S.D.N.Y. 2010), abrogated on other grounds by Chin v. Port Auth. of N.Y. & N.J., 685 F.3d 135 (2d Cir. 2012) (″The least harsh instruction permits (but does not require) a jury to presume that the lost evidence is both relevant and favorable to the innocent party.″).

2014Sec., 685 F.Supp.2d 456, 470 (S.D.N.Y. 2010), abrogated on other grounds by Chin v. Port Auth. of N.Y. & N.J., 685 F.3d 135 (2d Cir.2012) ("The least harsh instruction permits (but does not require) a jury to presume that the lost evidence is both relevant and favorable to the innocent party.”). .

12
Tran v. MacHagreen
tex · 2006 · cited in 1 Texas opinions naming this issue, 2018–2018
1 sentence

2018Because adverse possession is a harsh doctrine, the law requires that a party’s intention to appropriate property via adverse possession be “very clear.” Tran v. Macha, 213 S.W.3d 913, 915 (Tex. 2006). “[T]he mere grazing of land incidentally enclosed as a result of the construction of fences built for another purpose does not constitute possession that will ripen into title by limitation.

11
Hyett v. Stategreen
texapp · 2001 · cited in 1 Texas opinions naming this issue, 2006–2006
1 sentence

2006See King v. State, 895 S.W.2d 701, 702-04 (Tex.Crim.App.1995); 1 see also Joseph v. State, 897 S.W.2d 374, 376 (Tex.Crim.App.1995) (finding it error to require controlled substance to be visible to naked eye to support conviction; visibility not an element of possession of controlled substance); Hyett v. State, 58 S.W.3d 826, 831 (Tex.App.-Houston [14th Dist.] 2001, pet ref'd).

11
Joseph v. Stategreen
texcrimapp · 1995 · cited in 1 Texas opinions naming this issue, 2006–2006
1 sentence

2006See King v. State, 895 S.W.2d 701, 702-04 (Tex.Crim.App.1995); 1 see also Joseph v. State, 897 S.W.2d 374, 376 (Tex.Crim.App.1995) (finding it error to require controlled substance to be visible to naked eye to support conviction; visibility not an element of possession of controlled substance); Hyett v. State, 58 S.W.3d 826, 831 (Tex.App.-Houston [14th Dist.] 2001, pet ref'd).

11
Fax Telecommunicaciones v. AT & Tgreen
nyed · 1996 · cited in 1 Texas opinions naming this issue, 1999–1999
1 sentence

1999See Fax Telecommunicaciones, 952 F.Supp. at 952 .

11
Van Byrd v. Stategreen
texcrimapp · 1980 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995To have an opportunity to place the motion in writing and have it sworn to would sometimes require a delay of the trial until that matter could be completed, and the trial could often be expedited by allowing this motion to be oral and recorded by a court reporter. [6] Since Whitmore, the Court of Criminal Appeals has emphasized that a defendant is not entitled to a new trial merely because a co-defendant's testimony is "newly available." See Van Byrd v. State, 605 S.W.2d 265, 267 (Tex.Cr.App. 1980); Todd v. State, 601 S.W.2d 718, 720 (Tex.Cr.App.1980); Eddlemon v. State, 591 S.W.2d 847, 849 (

11
Todd v. Stategreen
texcrimapp · 1980 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995To have an opportunity to place the motion in writing and have it sworn to would sometimes require a delay of the trial until that matter could be completed, and the trial could often be expedited by allowing this motion to be oral and recorded by a court reporter. [6] Since Whitmore, the Court of Criminal Appeals has emphasized that a defendant is not entitled to a new trial merely because a co-defendant's testimony is "newly available." See Van Byrd v. State, 605 S.W.2d 265, 267 (Tex.Cr.App. 1980); Todd v. State, 601 S.W.2d 718, 720 (Tex.Cr.App.1980); Eddlemon v. State, 591 S.W.2d 847, 849 (

11
Bodde v. Stategreen
texcrimapp · 1978 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995The Court in McGlothlin recognized criticism of the DeGarmo doctrine as being “a harsh rule of law,” but explained the doctrine’s rationale as follows: The DeGarmo doctrine had been described as a “common-sense rule of procedure,” Bodde v. State, 568 S.W.2d 344, 348 (Tex.Cr.App.1978), because “the function of trial is to sift out the truth from a mass of contradictory evidence_” In re Michael, 326 U.S. 224, 227 , 66 S.Ct. 78, 80 , 90 L.Ed. 30 (1945).

11
Eddlemon v. Stategreen
texcrimapp · 1979 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995To have an opportunity to place the motion in writing and have it sworn to would sometimes require a delay of the trial until that matter could be completed, and the trial could often be expedited by allowing this motion to be oral and recorded by a court reporter. [6] Since Whitmore, the Court of Criminal Appeals has emphasized that a defendant is not entitled to a new trial merely because a co-defendant's testimony is "newly available." See Van Byrd v. State, 605 S.W.2d 265, 267 (Tex.Cr.App. 1980); Todd v. State, 601 S.W.2d 718, 720 (Tex.Cr.App.1980); Eddlemon v. State, 591 S.W.2d 847, 849 (

11
Jeanes v. Hambygreen
texapp · 1984 · cited in 1 Texas opinions naming this issue, 1988–1988
1 sentence

1988Jeanes v. Hamby, 685 S.W.2d 695, 699 (Tex.App.—Dallas 1984, writ ref’d n.r. e.).

11
Westinghouse Credit Corporation v. Kownslargreen
tex · 1973 · cited in 1 Texas opinions naming this issue, 1981–1981
11
Toni v. Kingan & Co.green
ind · 1938 · cited in 1 Texas opinions naming this issue, 1973–1973
11
Spencer v. Texas Factors, Inc.green
texapp · 1963 · cited in 1 Texas opinions naming this issue, 1972–1972
11
Ellis v. Mooregreen
tex · 1966 · cited in 1 Texas opinions naming this issue, 1968–1968
11
Halepeska v. Callihan Interests, Inc.red
tex · 1963 · cited in 1 Texas opinions naming this issue, 1968–1968
11
Federal Underwriters Exchange v. Bullardgreen
texapp · 1939 · cited in 1 Texas opinions naming this issue, 1952–1952
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 (49)

CaseCitedYears
Hejl v. Wirth green
tex · 1961
2 sentences

2009French v. Olive, 67 Tex. 400 , 3 S.W. 568 (1887); Permian Oil Co. v. Smith, 129 Tex. 413 , 73 S.W.2d 490 (1934), Hejl v. Wirth, 161 Tex. 609 , 343 S.W.2d 226 (1961).

2009French v. Olive, 67 Tex. 400 , 3 S.W. 568 (1887); Permian Oil Co. v. Smith, 129 Tex. 413 , 73 S.W.2d 490 (1934), Hejl v. Wirth, 161 Tex. 609 , 343 S.W.2d 226 (1961).

32009–2009
Permian Oil Co. v. Smith green
tex · 1937
2 sentences

2009French v. Olive, 67 Tex. 400 , 3 S.W. 568 (1887); Permian Oil Co. v. Smith, 129 Tex. 413 , 73 S.W.2d 490 (1934), Hejl v. Wirth, 161 Tex. 609 , 343 S.W.2d 226 (1961).

2009French v. Olive, 67 Tex. 400 , 3 S.W. 568 (1887); Permian Oil Co. v. Smith, 129 Tex. 413 , 73 S.W.2d 490 (1934), Hejl v. Wirth, 161 Tex. 609 , 343 S.W.2d 226 (1961).

32009–2009
French v. Olive green
tex · 1887
2 sentences

2009French v. Olive, 67 Tex. 400 , 3 S.W. 568 (1887); Permian Oil Co. v. Smith, 129 Tex. 413 , 73 S.W.2d 490 (1934), Hejl v. Wirth, 161 Tex. 609 , 343 S.W.2d 226 (1961).

2009French v. Olive, 67 Tex. 400 , 3 S.W. 568 (1887); Permian Oil Co. v. Smith, 129 Tex. 413 , 73 S.W.2d 490 (1934), Hejl v. Wirth, 161 Tex. 609 , 343 S.W.2d 226 (1961).

32009–2009
Doe v. Boys Clubs of Greater Dallas, Inc. green
texapp · 1994
2 sentences

1998“It would be a harsh rule indeed if an employer were held liable for any criminal act committed by an employee against a person who just happened to be a customer, client, or fellow employee of the employer.” Doe, 868 S.W.2d at 950 .

1998"It would be a harsh rule indeed if an employer were held liable for any criminal act committed by an employee against a person who just happened to be a customer, client, or fellow employee of the employer." Doe , 868 S.W.2d at 950 .

21998–1998
Morse v. Minneapolis & St. Louis Railway Co. green
minn · 1883
2 sentences

1893Indeed, it'would be a harsh rule if every change for the better was to be considered as evidence showing former negligence.’ 4 Texas Law Rev., 54, 56; Morse v. Railway, 30 Minn., 465 .” The point raised in the second assignment of error is, that “ The court erred in permitting plaintiff to prove by himself and his witnesses Jeff Haskell, T.

1889Indeed it would be a harsh rule if every change for the better is to he considered as evidence showing former negligence.” 4 Texas Law Rev., 54, 56; Morse v. Railway Co., 30 Minn., 465 .

21889–1893
McDonnold v. Weinacht green
tex · 1971
1 sentence

2018The adverse claimant who relies upon grazing only as evidence of his adverse use and enjoyment must show as part of his case that the land in dispute was designedly enclosed.” McDonnold v. Weinacht, 465 S.W.2d 136 , 141–42 (Tex. 1971).

12018–2018
Brookshire Brothers, Ltd. v. Jerry Aldridge green
tex · 2014
2 sentences

2015Michele Chimene Page 26 of 28 438 S.W.3d 9, *36 ; 2014 Tex. LEXIS 562 , **72 must find both intentional destruction10 and prejudice to the nonspoliating party.

2015Michele Chimene Page 26 of 28 438 S.W.3d 9, *36 ; 2014 Tex. LEXIS 562 , **72 must find both intentional destruction10 and prejudice to the nonspoliating party.

12015–2015
In Re Michael green
scotus · 1945
2 sentences

1995The Court in McGlothlin recognized criticism of the DeGarmo doctrine as being “a harsh rule of law,” but explained the doctrine’s rationale as follows: The DeGarmo doctrine had been described as a “common-sense rule of procedure,” Bodde v. State, 568 S.W.2d 344, 348 (Tex.Cr.App.1978), because “the function of trial is to sift out the truth from a mass of contradictory evidence_” In re Michael, 326 U.S. 224, 227 , 66 S.Ct. 78, 80 , 90 L.Ed. 30 (1945).

1995The Court in McGlothlin recognized criticism of the DeGarmo doctrine as being “a harsh rule of law,” but explained the doctrine’s rationale as follows: The DeGarmo doctrine had been described as a “common-sense rule of procedure,” Bodde v. State, 568 S.W.2d 344, 348 (Tex.Cr.App.1978), because “the function of trial is to sift out the truth from a mass of contradictory evidence_” In re Michael, 326 U.S. 224, 227 , 66 S.Ct. 78, 80 , 90 L.Ed. 30 (1945).

11995–1995
Tehan v. United States Ex Rel. Shott green
scotus · 1965
2 sentences

1995Stated another way, “The basic purpose of a trial is the determination of truth.” Tehan v. United States, 382 U.S. 406 , 86 S.Ct. 459 , 15 L.Ed.2d 453 (1966). [citations omitted] When the defendant testifies and judicially confesses to the charged offense, the purpose of the trial process has been served— the truth has been determined and the purpose of the guilt/innocence phase of the trial has been satisfied.

1995Stated another way, “The basic purpose of a trial is the determination of truth.” Tehan v. United States, 382 U.S. 406 , 86 S.Ct. 459 , 15 L.Ed.2d 453 (1966). [citations omitted] When the defendant testifies and judicially confesses to the charged offense, the purpose of the trial process has been served— the truth has been determined and the purpose of the guilt/innocence phase of the trial has been satisfied.

11995–1995
Madden v. State green
texcrimapp · 1990
1 sentence

1993As we recognized in Madden , “[a] challenge to the trial judge’s ruling on a motion for an instructed verdict is in actuality a challenge to the sufficiency of the evidence to support the conviction.” Madden, 799 S.W.2d at 686 .

11993–1993
Reed v. State green
texapp · 1934
1 sentence

1992Id.

11992–1992
Farley v. MM Cattle Company green
tex · 1975
2 sentences

1992Further, we recognized that "[a] plaintiff's burden to negate his own knowledge and appreciation ... overlaps and duplicates the voluntary assumption of risk doctrine," which this court abolished in Farley v. M M Cattle Company, 529 S.W.2d 751 (Tex.1975).

1992Further, we recognized that “[a] plaintiff’s burden to negate his own knowledge and appreciation ... overlaps and duplicates the voluntary assumption of risk doctrine,” which this court abolished in Farley v. M M Cattle Company, 529 S.W.2d 751 (Tex.1975).

11992–1992
Parker v. Highland Park, Inc. green
tex · 1978
2 sentences

1992It is a harsh doctrine and imports a distrust of juries." Id. at 519 .

1992It is a harsh doctrine and imports a distrust of juries.” Id. at 519 .

11992–1992
Pope & Talbot, Inc. v. Hawn green
scotus · 1953
2 sentences

1990The Supreme Court held that the harsh rule of contributory negligence that wholly barred recovery was completely incompatible with admiralty law which allows such consideration of contributory negligence only in mitigation of damages. 346 U.S. at 408-10 , 74 S.Ct. at 202 , 98 L.Ed. at 150-51 .

1990The Supreme Court held that the harsh rule of contributory negligence that wholly barred recovery was completely incompatible with admiralty law which allows such consideration of contributory negligence only in mitigation of damages. 346 U.S. at 408-10 , 74 S.Ct. at 202 , 98 L.Ed. at 150-51 .

11990–1990
American Savings & Loan Ass'n of Houston v. Musick green
tex · 1975
11979–1979
Tomlin v. State green
texcrimapp · 1960
11978–1978
Western & Atlantic R. v. Underwood neutral
gand · 1922
11973–1973
Great Northern Ry. Co. v. Hyder green
wawd · 1922
11972–1972
Rodriguez v. State green
texcrimapp · 1963
11972–1972
Fawcett v. State green
texcrimapp · 1939
11972–1972
Henger v. Sale neutral
tex · 1963
11970–1970
McCormick v. Cornell Wardlaw neutral
texapp · 1916
11970–1970
In Re King's Estate green
tex · 1951
11968–1968
James v. James green
texapp · 1923
11965–1965
Alvis v. McDonald neutral
texapp · 1955
11957–1957
Hutchins v. Birdsong green
texapp · 1953
11956–1956
Texas & Pacific Railway Co. v. Rea neutral
texapp · 1901
11954–1954
Armstrong v. State neutral
texapp · 1938
11950–1950
Commercial Credit Co. v. American Mfg. Co. green
texapp · 1941
11945–1945
Dublin Nat. Bank v. Chastain green
texapp · 1942
11945–1945
Consolidated Garage Co. v. Chambers neutral
tex · 1921
11945–1945
Motor Investment Co. v. City of Hamlin green
· 1944
11945–1945
Burmarsal Co. v. Lake neutral
texapp · 1925
11936–1936
Early-Foster Co. v. Mid-Tex Oil Mills green
texapp · 1918
11936–1936
Galbraith v. Bishop neutral
texcommnapp · 1926
11934–1934
Sibley v. Continental Supply Co. neutral
tex · 1927
11934–1934
Clark v. Shamrock Compress & Warehouse Co. neutral
texapp · 1930
11934–1934
City of Dallas v. Springer green
texapp · 1928
11934–1934
Texas & Pacific Railway Co. v. Phelps neutral
tex · 1927
11934–1934
Streight v. State green
· 1911
11931–1931

Statutes the citing opinions construe

TX § Tex. Prop. Code § 22.001 (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

CA 59 (1891–2026) TX 58 (1889–2018) NY 34 (1876–2025) PA 24 (1827–2018) IL 24 (1899–2020) MO 23 (1885–2016) FL 17 (1920–2010) GA 17 (1950–2012) KS 16 (1906–2022) IA 15 (1889–2018) OR 13 (1920–2025) OK 13 (1914–2001) LA 13 (1926–1994) WA 13 (1901–2009) CT 13 (1914–2010) WV 12 (1882–2003) MA 11 (1888–2018) NJ 10 (1950–2004) OH 10 (1914–2013) MI 10 (1926–1994) ID 9 (1966–2011) NC 9 (1911–2004) IN 9 (1890–2023) HI 9 (1923–2003) CO 9 (1930–2017) AL 8 (1895–1996) KY 8 (1917–2005) WI 8 (1900–2019) MN 7 (1947–1986) AR 7 (1978–2018) AZ 6 (1913–1979) TN 6 (1966–2005) SD 6 (1914–1996) MD 6 (1948–2014) ND 6 (1913–1991) VA 5 (1918–1998) SC 5 (1927–2001) WY 5 (1895–1988) VT 4 (1868–2014) MT 4 (1896–1947) RI 3 (1978–1999) NE 3 (1998–2019) AK 3 (1991–2019) DE 3 (1915–2021) NM 3 (1943–1995) VI 2 (1982–2014) NH 2 (1976–2018) DC 2 (1978–1980)

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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