non-liability rule (Texas) · Go Syfert
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non-liability rule in Texas

7 Texas opinions name it 2 courts 1955–2024 1 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 (7)

CaseFollowedCited
Lockheed Martin Corp. v. Gordongreen
texapp · 2000 · cited in 4 Texas opinions naming this issue, 2004–2019
2 sentences

2019Co., 626 F.3d 871, 877 (5th Cir. 2010)); Lockheed Martin Corp., 16 S.W.3d at 134, 139 (“Texas strongly embraces the non-liability rule.”).

2004See Suarez v. Sherman Gin Co. , 697 S.W.2d 17, 20-21 (Tex. App.—Dallas 1985, writ ref’d, n.r.e.) (contrasting stock and asset-purchase cases decided under pre-article 5.10(B)(2) law); see also Lockheed Martin Corp. v. Gordon, 16 S.W.3d 127, 139-40 (Tex. App.—Houston [1st Dist.] 2000, pet. denied) (“Texas strongly embraces the non-liability rule.”).

44
Suarez v. Sherman Gin Co.green
texapp · 1985 · cited in 2 Texas opinions naming this issue, 2004–2004
2 sentences

2004See Suarez v. Sherman Gin Co. , 697 S.W.2d 17, 20-21 (Tex. App.—Dallas 1985, writ ref’d, n.r.e.) (contrasting stock and asset-purchase cases decided under pre-article 5.10(B)(2) law); see also Lockheed Martin Corp. v. Gordon, 16 S.W.3d 127, 139-40 (Tex. App.—Houston [1st Dist.] 2000, pet. denied) (“Texas strongly embraces the non-liability rule.”).

2004See Suarez v. Sherman Gin Co., 697 S.W.2d 17, 20-21 (Tex.App.-Dallas 1985, writ ref d, n.r.e.) (contrasting *781 stock and asset-purchase cases decided under pre-article 5.10(B)(2) law); see also Lockheed Martin Corp. v. Gordon, 16 S.W.3d 127, 139-40 (Tex.App.-Houston [1st Dist.] 2000, pet. denied) (“Texas strongly embraces the non-liability rule.”).

22
Lone Star Air Systems, LTD v. David Powersgreen
texapp · 2013 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024The only exception to this non-liability rule is that a shareholder may be held liable for such corporate obligations “if the obligee demonstrates that the [shareholder] caused the corporation to be used for the purpose of perpetrating and did perpetrate an actual fraud on the obligee primarily for the direct personal benefit of the [shareholder].” Id. § 21.223(b); see Lone Star Air Sys., Ltd. v. Powers, 401 S.W.3d 855, 862 (Tex. App.—Houston [14th Dist.] 2013, no pet.).

11
Keller Foundations, Inc. v. Wausau Underwriters Insurancegreen
ca5 · 2010 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019Co., 626 F.3d 871, 877 (5th Cir. 2010)); Lockheed Martin Corp., 16 S.W.3d at 134, 139 (“Texas strongly embraces the non-liability rule.”).

11
E-Quest Management, L.L.C. and Odyssey OneSource, Inc. v. Robbie Shawgreen
texapp · 2013 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See E-Quest Mgmt., L.L.C. v. Shaw, 433 S.W.3d 18 , 23–24 (Tex. App.—Houston [1st Dist.] 2013, pet. denied); Lockheed Martin Corp. v. Gordon, 16 S.W.3d 127, 139 (Tex. App.—Houston [1st Dist.] –10– 2000, pet. denied).

11
Marshall v. International Longshoremen's & Warehousemen's Uniongreen
cal · 1962 · cited in 1 Texas opinions naming this issue, 1992–1992
2 sentences

1992Rather than abandoning the non-liability rule, the Court could have used a test similar to the one announced by the California Supreme Court in Marshall v. International Longshoremen's and Warehousemen’s Union, 57 Cal.2d 781 , 22 Cal.Rptr. 211 , 371 P.2d 987, 990 (1962), which determines whether liability can accrue against an unincorporated association by asking: (1) whether the association possesses a separate legal existence from its members; and (2) whether the members retain direct control over the operations of the association.

1992Rather than abandoning the non-liability rule, the Court could have used a test similar to the one announced by the California Supreme Court in Marshall v. International Longshoremen's and Warehousemen’s Union, 57 Cal.2d 781 , 22 Cal.Rptr. 211 , 371 P.2d 987, 990 (1962), which determines whether liability can accrue against an unincorporated association by asking: (1) whether the association possesses a separate legal existence from its members; and (2) whether the members retain direct control over the operations of the association.

11
Zehner v. Wilkinson Memorial United Methodist Churchgreen
pa · 1990 · cited in 1 Texas opinions naming this issue, 1992–1992
2 sentences

1992Id. at 375 ; see also Marshall v. International Longshoremen's and Warehousemen's Union, 57 Cal.2d 781 , 22 Cal.Rptr. 211, 214 , 371 P.2d 987, 990 (1962). [3] In Zehner v. Wilkinson Memorial United Methodist Church , another case involving a church's liability to a member for negligence, a woman was injured when she slipped and fell on the church's steps while leaving after Christmas services. 581 A.2d at 1388 .

1992Id. at 375 ; see also Marshall v. International Longshoremen’s and Warehousemen’s Union, 57 Cal.2d 781 , 22 Cal.Rptr. 211, 214 , 371 P.2d 987, 990 (1962). 3 In Zehner v. Wilkinson Memorial United Methodist Church, another case involving a church’s liability to a member for negligence, a woman was injured when she slipped and fell on the church’s steps while leaving after Christmas services. 581 A.2d at 1388 .

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 (3)

CaseCitedYears
Calvary Baptist Church v. Joseph green
ind · 1988
2 sentences

1992Id. at 375 ; see also Marshall v. International Longshoremen's and Warehousemen's Union, 57 Cal.2d 781 , 22 Cal.Rptr. 211, 214 , 371 P.2d 987, 990 (1962). [3] In Zehner v. Wilkinson Memorial United Methodist Church , another case involving a church's liability to a member for negligence, a woman was injured when she slipped and fell on the church's steps while leaving after Christmas services. 581 A.2d at 1388 .

1992Id. at 375 ; see also Marshall v. International Longshoremen’s and Warehousemen’s Union, 57 Cal.2d 781 , 22 Cal.Rptr. 211, 214 , 371 P.2d 987, 990 (1962). 3 In Zehner v. Wilkinson Memorial United Methodist Church, another case involving a church’s liability to a member for negligence, a woman was injured when she slipped and fell on the church’s steps while leaving after Christmas services. 581 A.2d at 1388 .

11992–1992
Dutcher v. Owens green
tex · 1983
2 sentences

1992Cf. Dutcher v. Owens, 647 S.W.2d 948 (Tex.1983). [4] Since a majority of jurisdictions still apply the non-liability rule for unincorporated associations, it is axiomatic that abrogating imputed contributory negligence for bailments does not render it useless in other contexts. [5] As the Court notes, the Texas Legislature has refused to expand the non-liability rule contained in article 6133, which says that an "unincorporated joint stock company or association, whether foreign or domestic, doing business in this State, may sue or be sued...." at 171 (citing Tex.RevCiv.Stat. art. 6133 (1907))

1992Cf. Dutcher v. Owens, 647 S.W.2d 948 (Tex.1983). .

11992–1992
City of Houston v. Wolverton green
tex · 1955
2 sentences

1955In the more recent case of City of Houston v. Wolverton, 154 Texas 325 , 277 S.W. 2d 101 , we adhered to that position.

1955In the more recent case of City of Houston v. Wolverton, 154 Texas 325 , 277 S.W. 2d 101 , we adhered to that position.

11955–1955

Where else courts name it

TX 7 (1955–2024) NJ 4 (1924–2021) MO 3 (1997–2013) LA 3 (1948–2002) WY 2 (1990–2003) PA 2 (1865–1958) WA 2 (1897–1953) IL 2 (1929–1989) WI 2 (1923–1942)

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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