overruled challenge (Texas) · Go Syfert
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overruled challenge in Texas

48 Texas opinions name it 3 courts 1934–2024 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 (23)

CaseFollowedCited
Barefoot v. Stategreen
texcrimapp · 1980 · cited in 3 Texas opinions naming this issue, 1988–2008
2 sentences

2008See id.

2008See id.

23
Gollihar v. Stategreen
texcrimapp · 2001 · cited in 2 Texas opinions naming this issue, 2009–2009
2 sentences

2009Id. at 250, 257 .

2009Id. at 250, 257 .

22
Arline v. Stategreen
texcrimapp · 1986 · cited in 2 Texas opinions naming this issue, 2007–2007
2 sentences

2007Arline v. State, 721 S.W.2d 348, 351 (Tex.Crim.App. 1986) (Emphasis in original).

2007Arline v. State , 721 S.W.2d 348, 351 (Tex.Crim.App. 1986) (Emphasis in original).

22
Howland v. Stategreen
texapp · 1998 · cited in 2 Texas opinions naming this issue, 2006–2006
2 sentences

2006See id.

2006See id.

22
Everett v. Stategreen
texcrimapp · 1986 · cited in 2 Texas opinions naming this issue, 2002–2002
2 sentences

2002See Everett v. State, 707 S.W.2d 638, 641 (Tex.Crim.App.1986).

2002See Everett v. State , 707 S.W.2d 638, 641 (Tex. Crim.

22
Jackson v. Stategreen
texcrimapp · 2000 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024App. 2005) (stating that State may comment on defendant’s failure to call certain witnesses and such comment is not impermissible attempt to shift burden of proof); Jackson v. State, 17 S.W.3d 664, 674 (Tex. Crim.

11
Bible v. Stategreen
texcrimapp · 2005 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024In this case, the trial court overruled the defense’s objection to comments on evidence outside the record, but it sustained the objection as to “burden shifting.” We have previously noted that “[o]ur courts have consistently held that the State may argue in its closing argument that the defendant failed to present evidence in his favor.” Trevino v. State, 474 S.W.3d 737, 749 (Tex. App.—Beaumont 2014, pet. ref’d).3 The State contends that under Trevino, the prosecutor’s complained of 3 Citing to Bible v. State, 162 S.W.3d 234, 249 (Tex. Crim.

11
Boulware v. Stategreen
texcrimapp · 1976 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023“A failure to object timely waives any error in the admission of evidence and presents nothing for review.” Sullivan v. State, 678 S.W.2d 162, 169 (Tex. App.—Houston [1st Dist.] 1984, pet. ref’d) (citing Boulware v. State, 542 S.W.2d 677, 682 (Tex. Crim.

11
Sullivan v. Stategreen
texapp · 1984 · cited in 1 Texas opinions naming this issue, 2023–2023
1 sentence

2023“A failure to object timely waives any error in the admission of evidence and presents nothing for review.” Sullivan v. State, 678 S.W.2d 162, 169 (Tex. App.—Houston [1st Dist.] 1984, pet. ref’d) (citing Boulware v. State, 542 S.W.2d 677, 682 (Tex. Crim.

11
Bird v. Stategreen
texcrimapp · 1985 · cited in 1 Texas opinions naming this issue, 2019–2019
1 sentence

2019The State refers us to Bird v. State, 692 S.W.2d 65, 70 (Tex. Crim.

11
Brown v. Stategreen
texcrimapp · 1994 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016On appeal, we review the trial judge’s conclusion as to whether there is a factual dispute between the jurors for an abuse of discretion.131 We apply this same standard in reviewing the trial court’s selection of testimony responsive to the jury’s request.132 “A trial judge abuses his discretion when his decision is so clearly wrong as to lie outside the zone within which reasonable persons might disagree.” 133 The test for abuse of discretion is not 131 Howell, 175 S.W.3d at 790 . 132 See, e.g., Brown v. State, 870 S.W.2d 53, 56 (Tex. Crim.

11
Buckley v. Stategreen
texapp · 1988 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016On appeal, he notes that some intermediate appellate courts have enumerated eleven “indicia of reliability” that a trial court may consider in determining the reliability of a child’s outcry. 4 See Buckley v. State, 758 S.W.2d 339, 343-44 (Tex. App.—Texarkana 1988), aff'd on other grounds, 786 S.W.2d 357 (Tex. Crim.

11
Paulson v. Stategreen
texcrimapp · 2000 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Paulson v. State, 28 S.W.3d 570, 573 (Tex. Crim.

11
Flowers v. Stategreen
texcrimapp · 2007 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015The Texas Court of Criminal Appeals has decided this issue in Flowers v. State, 220 S.W.3d 919, 921-922 (Tex. Crim.

11
Barnes v. Stategreen
texcrimapp · 1994 · cited in 1 Texas opinions naming this issue, 2012–2012
1 sentence

2012Barnes v. State, 876 S.W.2d 316, 328 (Tex. Crim.

11
Rezac v. Stategreen
texcrimapp · 1990 · cited in 1 Texas opinions naming this issue, 2010–2010
1 sentence

2010See Rezac, 782 S.W.2d at 869–70. -9- 04-09-00634-CR CONCLUSION Because Quiroz failed to preserve error as to Officer Rosas’s opinion testimony that Quiroz committed a crime, and as to his claim that he was entitled to impeach Gover for bias, the trial court committed no reversible error.

11
Clark v. McFerringreen
texapp · 1988 · cited in 1 Texas opinions naming this issue, 2002–2002
1 sentence

2002In a footnote, the court overruled that challenge, observing that in instances in which a motion to modify a judgment is filed before a corrected judgment is signed, it is sufficient to extend the time for filing a notice of appeal for 90 days after the corrected judgment is signed, "as long as the substance of the motion is such as could properly be raised with respect to the corrected judgment." Id. at 770 n.3 ( citing Clark v. McFerrin , 760 S.W.2d 822, 825 (Tex.App.--Corpus Christi 1988, writ denied)).

11
King v. Stategreen
texcrimapp · 1997 · cited in 1 Texas opinions naming this issue, 1999–1999
11
Rousseau v. Stategreen
texcrimapp · 1992 · cited in 1 Texas opinions naming this issue, 1994–1994
11
Cumbo v. Stategreen
texcrimapp · 1988 · cited in 1 Texas opinions naming this issue, 1993–1993
11
Harris v. Stategreen
texcrimapp · 1989 · cited in 1 Texas opinions naming this issue, 1991–1991
11
Sanne v. Stategreen
texcrimapp · 1980 · cited in 1 Texas opinions naming this issue, 1983–1983
11
Lopez v. Stategreen
texcrimapp · 1948 · cited in 1 Texas opinions naming this issue, 1980–1980
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
Franklin v. State green
texcrimapp · 2004
2 sentences

2015Id. at 352 .

2015Id. at 352 .

22015–2015
Head v. State green
texcrimapp · 1999
2 sentences

2008Id.

2008Id.

22008–2008
Smith v. State green
texapp · 1988
2 sentences

2007Id.

2007Id.

22007–2007
Orona v. State green
texcrimapp · 1990
1 sentence

2019Id. at 129 .

12019–2019
Page v. State green
texapp · 2003
1 sentence

2018The trial court overruled defense counsel’s objections and admitted the recording into evidence.1 In reliance on Page v. State, 125 S.W.3d 640 (Tex. App.—Houston [1st Dist.] 2003, pet. ref’d), Appellant maintains that the recordings in this case were not sufficiently authenticated because (1) Ridgeway did not testify to the security system’s functionality and had little involvement in accessing, recording, and producing the video, and the office assistant would have been the proper witness for authenticating the recording, and (2) Abderrahman’s father handles the surveillance system, Abderrahm

12018–2018
Howell v. State green
texcrimapp · 2005
1 sentence

2016On appeal, we review the trial judge’s conclusion as to whether there is a factual dispute between the jurors for an abuse of discretion.131 We apply this same standard in reviewing the trial court’s selection of testimony responsive to the jury’s request.132 “A trial judge abuses his discretion when his decision is so clearly wrong as to lie outside the zone within which reasonable persons might disagree.” 133 The test for abuse of discretion is not 131 Howell, 175 S.W.3d at 790 . 132 See, e.g., Brown v. State, 870 S.W.2d 53, 56 (Tex. Crim.

12016–2016
Buckley v. State green
texcrimapp · 1990
1 sentence

2016On appeal, he notes that some intermediate appellate courts have enumerated eleven “indicia of reliability” that a trial court may consider in determining the reliability of a child’s outcry. 4 See Buckley v. State, 758 S.W.2d 339, 343-44 (Tex. App.—Texarkana 1988), aff'd on other grounds, 786 S.W.2d 357 (Tex. Crim.

12016–2016
Gilbert v. State green
texcrimapp · 1991
1 sentence

2016Id.

12016–2016
Rogers v. State green
texapp · 1987
1 sentence

2014Context and Understanding of Appellant’s Complaints We note that Appellant cites Rogers v. State, 725 S.W.2d 350 (Tex. App.—Houston [1st Dist.] 1987, no pet.), as support for finding prosecutorial misconduct in this case.

12014–2014
Green v. State green
texapp · 1994
1 sentence

2011Id.

12011–2011
Mosley v. State green
texcrimapp · 1998
1 sentence

2006This case is similar to Mosley in that (1) the trial court did not take any curative action and (2) the prosecutor continued with his remarks after the trial court overruled the defense’s objections, making further reference to the fingerprint defense as a “rabbit trail.” Nevertheless, we also conclude, as did the Mosley court, that the third factor, the certainty of conviction without the misconduct , “weighs heavily in favor of the State.” Id.

12006–2006
Dunn v. City of Tyler green
texapp · 1993
1 sentence

2002Similarly, in Dunn v. City of Tyler , 848 S.W.2d 305 (Tex.App.--Eastland 1993, no writ), the court held that a motion for new trial relating to an earlier judgment may be considered as a premature motion, and thus be effective to extend the time for filing an appeal bond (then necessary to perfect appeal) for 90 days after the date of a corrected judgment when the substance of the motion was such as could properly be raised with respect to the corrected judgment.

12002–2002
Maddox v. Cosper green
texapp · 2000
1 sentence

2002In a footnote, the court overruled that challenge, observing that in instances in which a motion to modify a judgment is filed before a corrected judgment is signed, it is sufficient to extend the time for filing a notice of appeal for 90 days after the corrected judgment is signed, "as long as the substance of the motion is such as could properly be raised with respect to the corrected judgment." Id. at 770 n.3 ( citing Clark v. McFerrin , 760 S.W.2d 822, 825 (Tex.App.--Corpus Christi 1988, writ denied)).

12002–2002
Elbaor v. Smith green
tex · 1993
11996–1996
Anderson v. State green
texapp · 1994
11994–1994
Self v. State green
texapp · 1993
11993–1993
Woods v. Texas green
scotus · 1981
11988–1988
Hernandez v. State green
texcrimapp · 1978
11988–1988
Witherspoon v. Illinois green
scotus · 1968
11985–1985
Adams v. Texas green
scotus · 1980
11985–1985
Compton v. Henrie green
tex · 1963
11972–1972
McBride v. United Irr. Co. neutral
texapp · 1919
11959–1959
Culver v. Pickens neutral
texapp · 1943
11948–1948
Golden v. Odiorne green
tex · 1923
11934–1934
T. C. R'y Co. v. Burnett neutral
tex · 1884
11934–1934

Statutes the citing opinions construe

TX § Tex. Penal Code § 22.021 (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 52 (1959–2026) TX 48 (1934–2024) LA 48 (1866–2019) OH 30 (1995–2025) FL 26 (1984–2019) IL 22 (1918–2026) AL 16 (1958–2001) MI 15 (1877–2019) MO 14 (1894–2022) NY 14 (1844–2014) GA 9 (1951–2026) WA 8 (1905–2019) MS 7 (1963–2018) NC 7 (1859–2026) PA 7 (1978–2019) MD 7 (1990–2022) CT 6 (1971–2021) HI 6 (1906–2018) OK 6 (1929–2022) AR 6 (1916–2021) IN 5 (1976–2000) TN 5 (2011–2022) DC 5 (1986–2024) CO 5 (1983–2025) KY 5 (1995–2024) VA 4 (1900–2018) SC 4 (1935–1998) NJ 4 (1950–2026) KS 3 (1925–2004) OR 3 (2020–2025) NE 2 (1987–2013) IA 2 (1935–2020) UT 2 (1998–2013) AZ 2 (2006–2012) WV 2 (1928–2001)

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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