sustained defense (Texas) · Go Syfert
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sustained defense in Texas

49 Texas opinions name it 5 courts 1891–2025 5 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 (20)

CaseFollowedCited
Chambers v. Stategreen
texcrimapp · 1993 · cited in 4 Texas opinions naming this issue, 2004–2008
2 sentences

2008Chambers v. State, 866 S.W.2d 9, 22 (Tex.Crim.App. 1993), citing Cantu v. State, 842 S.W.2d 667, 681 (Tex.Crim.App. 1992).

2008Chambers v. State, 866 S.W.2d 9, 22 (Tex.Crim.App. 1993), citing Cantu v. State, 842 S.W.2d 667, 681 (Tex.Crim.App. 1992).

44
Cantu v. Stategreen
texcrimapp · 1992 · cited in 4 Texas opinions naming this issue, 2004–2008
2 sentences

2008Chambers v. State, 866 S.W.2d 9, 22 (Tex.Crim.App. 1993), citing Cantu v. State, 842 S.W.2d 667, 681 (Tex.Crim.App. 1992).

2008Chambers v. State, 866 S.W.2d 9, 22 (Tex.Crim.App. 1993), citing Cantu v. State, 842 S.W.2d 667, 681 (Tex.Crim.App. 1992).

44
Wesbrook v. Stategreen
texcrimapp · 2000 · cited in 3 Texas opinions naming this issue, 2004–2024
2 sentences

2024The trial court stated, “Disregard the prosecutor’s last comment.” “In most instances, an instruction to disregard the remarks will cure the error.” Wesbrook v. State, 29 S.W.3d 103, 115 (Tex. Crim.

2005See Wesbrook, 29 S.W.3d at 115 ; Phillips v. State, 130 S.W.3d 343, 355-56 (Tex.App.-Houston [14th Dist.] 2004, no pet. h.).

33
Hawkins v. Stategreen
texcrimapp · 2004 · cited in 4 Texas opinions naming this issue, 2008–2025
2 sentences

2025Hawkins v. State, 135 S.W.3d 72 , 76–77 (Tex. Crim.

2014Hawkins, 135 S.W.3d at 76–77.

24
Phillips v. Stategreen
texapp · 2004 · cited in 2 Texas opinions naming this issue, 2004–2005
2 sentences

2005See Wesbrook, 29 S.W.3d at 115 ; Phillips v. State, 130 S.W.3d 343, 355-56 (Tex.App.-Houston [14th Dist.] 2004, no pet. h.).

2004See Wesbrook , 29 S.W.3d at 115 ; Phillips v. State , 130 S.W.3d 343, 355-56 (Tex. App.—Houston [14th Dist.] 2004, no pet. h.).

22
Wages v. Stategreen
texapp · 1985 · cited in 2 Texas opinions naming this issue, 1998–1998
2 sentences

1998Poole cites us to Wages v. State in which the court held that it was error for the State to ask the jury to punish the defendant for exercising his right to trial. 703 S.W.2d 736, 741 (Tex.App.—Houston [14th Dist.] 1985, pet. dism’d).

1998Poole cites us to Wages v. State in which the court held that it was error for the State to ask the jury to punish the defendant for exercising his right to trial. 703 S.W.2d 736, 741 (Tex. App.--Houston [14th Dist.] 1985, pet. dism'd).

22
Randolph, Emanuell Glenngreen
texcrimapp · 2011 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024See Randolph v. State, 353 S.W.3d 887, 891 (Tex. Crim.

11
Garcia v. Stategreen
texcrimapp · 2004 · cited in 1 Texas opinions naming this issue, 2022–2022
1 sentence

2022See Garcia v. State, 126 S.W.3d 921, 924 (Tex. Crim.

11
Gamboa v. Stategreen
texcrimapp · 2009 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019Gamboa v. State, 296 S.W.3d 574, 580 (Tex. Crim.

11
Wilkerson v. Stategreen
texcrimapp · 1994 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019The jury charge also instructed the jury that the “law does not require a defendant to prove his innocence or produce any evidence at all.” An instruction to the jury to disregard improper jury argument cures the error unless the remark is “so inflammatory that its prejudicial effect could not reasonably be overcome by such an instruction.” Wilkerson v. State, 881 S.W.2d 321, 327 (Tex. Crim.

11
In Re Arroyogreen
tex · 1998 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See generally In re Arroyo, 988 S.W.2d 737, 739 (Tex. 1998) (holding that the amended Rules of Appellate Procedure provided an adequate appellate remedy that was functionally identical to 6 mandamus review previously used to review an order in which the trial court sustained a challenge to an affidavit of indigence).

11
Chamberlain v. Stategreen
texcrimapp · 1999 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015He notes that, at the guilt-innocence phase of trial, defense counsel moved for mistrial at least twenty-five times and the trial court issued at least nine instructions to disregard inadmissible testimony or improper argument offered by the State.15 15In particular, the trial court sustained defense counsel’s objections and issued instructions to disregard as to the following: (1) A statement by Novoa agreeing with the prosecutor that Y.M. was “forthcoming” with answers to questions that she posed during her interview; (2) A statement by Novoa agreeing with the prosecutor that Y.M. “freely g[

11
Archie v. Stategreen
texcrimapp · 2007 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See Archie v. State, 221 S.W.3d 695, 699 (Tex. Crim.

11
Carter v. Stategreen
texcrimapp · 1986 · cited in 1 Texas opinions naming this issue, 2006–2006
1 sentence

2006P. 33.1(a)(1), (2); cf. Carter v. State, 717 S.W.2d 60, 72, 76 (Tex.Crim.App.1986) (noting, “The court sustained the challenge for cause by the State.

11
Cates v. Stategreen
texapp · 1988 · cited in 1 Texas opinions naming this issue, 1999–1999
1 sentence

1999See Cates v. State, 752 S.W.2d 175, 176 (Tex.App.—Dallas 1988, no pet.) (holding that even where the court sustained defense counsel’s objection to the prosecution’s comment on defendant’s failure to testify any error was cured and rendered harmless by the court’s instruction to disregard).

11
Huffman v. Stategreen
texcrimapp · 1988 · cited in 1 Texas opinions naming this issue, 1998–1998
1 sentence

1998The general rule is that error incurred as a result of an improper question “may be cured or rendered harmless by its withdrawal or an instruction to disregard,” unless the question was “clearly calculated to inflame the minds of the jury and is of such a character so as to suggest the impermissibility of withdrawing the impression produced.” Huffman v. State, 746 S.W.2d 212, 218 (Tex.Crim.App.1988); Carter v. State, 614 S.W.2d 821, 824 (Tex.Crim.App. [Panel Op.] 1981).

11
Carter v. Stategreen
texcrimapp · 1981 · cited in 1 Texas opinions naming this issue, 1998–1998
1 sentence

1998The general rule is that error incurred as a result of an improper question “may be cured or rendered harmless by its withdrawal or an instruction to disregard,” unless the question was “clearly calculated to inflame the minds of the jury and is of such a character so as to suggest the impermissibility of withdrawing the impression produced.” Huffman v. State, 746 S.W.2d 212, 218 (Tex.Crim.App.1988); Carter v. State, 614 S.W.2d 821, 824 (Tex.Crim.App. [Panel Op.] 1981).

11
Orona v. Stategreen
texcrimapp · 1990 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995See Ramos v. State, 767 S.W.2d 248, 252 (Tex.App.—Corpus Christi 1989, pet. ref'd) (any harm that may have occurred by an accusation by prosecution that defense counsel is playing on the jury’s sympathy would be cured by an instruction to disregard); see also Orona, 791 S.W.2d at 129-130 (statement by prosecution that defense counsel was adept at getting criminal defendants “off the hook” did not contribute to conviction).

11
Ramos v. Stategreen
texapp · 1989 · cited in 1 Texas opinions naming this issue, 1995–1995
1 sentence

1995See Ramos v. State, 767 S.W.2d 248, 252 (Tex.App.—Corpus Christi 1989, pet. ref'd) (any harm that may have occurred by an accusation by prosecution that defense counsel is playing on the jury’s sympathy would be cured by an instruction to disregard); see also Orona, 791 S.W.2d at 129-130 (statement by prosecution that defense counsel was adept at getting criminal defendants “off the hook” did not contribute to conviction).

11
Fambrough v. Wagleygreen
tex · 1943 · cited in 1 Texas opinions naming this issue, 1979–1979
2 sentences

1979Fambrough v. Wagley, 140 Tex. 577, 585 , 169 S.W.2d 478, 482 (1943).

1979Fambrough v. Wagley, 140 Tex. 577, 585 , 169 S.W.2d 478, 482 (1943).

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 (25)

CaseCitedYears
Veteto v. State green
texapp · 2000
2 sentences

2003In Veteto v. State, 8 S.W.3d 805 (Tex.App.-Waco 2000, pet. ref'd), the trial court sustained defense objections at trial, based primarily on the Fifth Amendment, and instructed the jury to disregard because “post-arrest silence” was not evidence.

2003In Veteto v. State, 8 S.W.3d 805 (Tex.App.-Waco 2000, pet. ref'd), the trial court sustained defense objections at trial, based primarily on the Fifth Amendment, and instructed the jury to disregard because "post-arrest silence" was not evidence.

22003–2003
Garrett v. State green
texcrimapp · 1993
2 sentences

1995Id. at 859 .

1995Id. at 859 .

21995–1995
Stillwell v. City of Fort Worth neutral
texapp · 1942
2 sentences

1943The Court of Civil Appeals affirmed the judgment. 162 S.W.2d 1046 .

1943The Court of Civil Appeals affirmed the judgment. 162 S. W. (2d) 1046 .

21943–1943
Garza v. Attorney General green
texapp · 2005
1 sentence

2021Within this timeframe, Gordon Haley filed his 2021 statement, Wilmington filed its challenge to the statement, and the trial court sustained the challenge. 6 the declarant to prove the inability to afford costs.” Id.

12021–2021
Mendoza v. Ranger Insurance Co. green
texapp · 1988
1 sentence

2019Id. at 779–80.

12019–2019
Helleson v. State green
texapp · 1999
1 sentence

2019Id.

12019–2019
Reyna v. State green
texcrimapp · 2005
1 sentence

2013Appellant’s objections to the prosecutor’s questions that the trial court overruled were not made on the basis of the Confrontation Clause; thus, those objections did not preserve his Confrontation Clause issue on appeal. 2 See Reyna, 168 S.W.3d at 179 ; Paredes, 129 S.W.3d at 535 ; see also Cavil, 2009 WL 2617780 , at *3.

12013–2013
Paredes v. State green
texcrimapp · 2004
1 sentence

2013Appellant’s objections to the prosecutor’s questions that the trial court overruled were not made on the basis of the Confrontation Clause; thus, those objections did not preserve his Confrontation Clause issue on appeal. 2 See Reyna, 168 S.W.3d at 179 ; Paredes, 129 S.W.3d at 535 ; see also Cavil, 2009 WL 2617780 , at *3.

12013–2013
Ramos v. State green
texcrimapp · 1967
2 sentences

1985Initially, as was stated in Ramos v. State, 419 S.W.2d 359 (Tex.Cr.App.1967), it is well settled that the prosecutor may argue his opinions concerning issues in the case so long as the opinions are based on the evidence in the record and not as constituting unsworn testimony.

1985Initially, as was stated in Ramos v. State, 419 S.W.2d 359 (Tex.Cr.App. 1967), it is well settled that the prosecutor may argue his opinions concerning issues in the case so long as the opinions are based on the evidence in the record and not as constituting unsworn testimony.

11985–1985
Porter v. Southwestern Public Service Company green
texapp · 1972
1 sentence

1984Similarly, in Porter v. Southwestern Public Service Co., 489 S.W.2d 361 (Tex.Civ.App.-Amarillo 1972, writ ref'd n.r.e.), the court held that, absent a sustained challenge, a city did not usurp the eminent domain power of a public utility by requiring it to meet certain standards under city zoning ordinances.

11984–1984
Mischer v. Frost neutral
texapp · 1970
11971–1971
Krueger, Hutchinson & Overton Clinic v. Lewis green
texapp · 1954
11954–1954
Hedgecroft v. City of Houston green
texapp · 1951
11951–1951
Vyvial v. State green
texcrimapp · 1928
11948–1948
Ezell v. Dodson green
tex · 1883
11938–1938
McKinney v. Southwestern Liqour Co. neutral
texapp · 1918
11931–1931
Waters-Pierce Oil Company v. State neutral
texapp · 1907
11928–1928
Mann v. Mitchell neutral
texapp · 1922
11923–1923
Mud Creek Irrigation, Agricultural, & Manufacturing Co. v. Vivian green
tex · 1889
11920–1920
Lee v. British-American Mortgage Co. green
texapp · 1908
11917–1917
Ralls v. Parish green
texapp · 1912
11917–1917
Harle v. Texas Southern Railway neutral
· 1905
11917–1917
Cooper v. Singleton green
tex · 1857
11891–1891
Carson v. Kelley & Sweatt neutral
tex · 1882
11891–1891
Fagan v. McWhirter neutral
tex · 1888
11891–1891

Statutes the citing opinions construe

TX § Tex. Penal Code § 12.32 (3) TX § Tex. Penal Code § 19.03 (3) TX § Tex. Penal Code § 22.011 (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

LA 114 (1897–2025) NY 68 (1916–2024) IL 67 (1898–2025) CA 60 (1984–2026) TX 49 (1891–2025) OH 25 (1999–2024) PA 25 (1892–2024) MI 18 (1901–2025) WA 16 (1922–2024) FL 15 (1993–2021) GA 12 (1981–2026) MS 11 (1959–2024) MD 10 (1934–2013) NC 10 (1890–2023) AL 9 (1987–2013) NJ 8 (1900–2014) MO 8 (1885–1995) OK 7 (1930–2009) TN 7 (1926–2015) MN 6 (1901–2007) KY 6 (1908–2025) CT 6 (1941–2025) IA 5 (1908–2026) KS 5 (1986–2024) VA 5 (1908–1985) WV 4 (1936–1974) CO 4 (2022–2025) AZ 4 (1994–2022) HI 4 (1944–2019) SC 3 (1912–2006) AR 3 (1918–2012) NM 3 (1946–1946) DC 3 (1976–2016) IN 3 (1861–1892) ID 3 (1972–2010) MA 2 (1961–1986) ND 2 (1911–1940) MT 2 (1895–1897) AK 2 (1982–2021) WI 2 (1899–2022) UT 2 (1917–2018) OR 2 (2006–2026)

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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