Thompson doctrine in Texas

47 Texas opinions name it 4 courts 1942–2026 4 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 (15)

Case	Followed	Cited
Thompson v. Mannixgreen texapp · 1991 · cited in 4 Texas opinions naming this issue, 2004–2004 2 sentences 2004Furthermore, in Thompson v. Mannix , 814 S.W.2d 811, 812 (Tex. App.-Waco 1991, no writ) the reviewing court concluded that the trial court could have justifiably invoked the doctrine to dismiss Thompson's claim for damages. 2004Furthermore, in Thompson v. Mannix , 814 S.W.2d 811, 812 (Tex. App.-Waco 1991, no writ) the reviewing court concluded that the trial court could have justifiably invoked the doctrine to dismiss Thompson's claim for damages.	4	4
Butler v. Stategreen texcrimapp · 1989 · cited in 3 Texas opinions naming this issue, 1994–2010 2 sentences 2010See Butler, 769 S.W.2d at 239 (likening the “any evidence'' test to a no-evidence rule that “differs not at all from” the Thompson standard abandoned in Jackson). 2010See Butler, 769 S.W.2d at 239 (likening the “any evidence'' test to a no-evidence rule that “differs not at all from” the Thompson standard abandoned in Jackson).	3	3
Ruffin v. Stategreen texapp · 1999 · cited in 3 Texas opinions naming this issue, 2001–2008 2 sentences 2008See Ruffin, 3 S.W.3d at 144 . 2001See Ruffin, 3 S.W.3d at 144 .	3	3
Combs v. Stategreen texcrimapp · 1982 · cited in 3 Texas opinions naming this issue, 1987–1994 2 sentences 1994Nevertheless, whether the evidence satisfies the current Jackson test is a "question of law." Combs v. State, 643 S.W.2d 709, 716 (Tex.Crim.App.1982), overruled on other grounds, Butler v. State, 769 S.W.2d 234, 239 (Tex.Crim.App.1989) and Meraz v. State, 785 S.W.2d 146, 155 (Tex.Crim.App.1990) (emphasis in original). 1994Nevertheless, whether the evidence satisfies the current Jackson test is a "question of law." Combs v. State, 643 S.W.2d 709, 716 (Tex.Crim.App.1982), overruled on other grounds, Butler v. State, 769 S.W.2d 234, 239 (Tex.Crim.App.1989) and Meraz v. State, 785 S.W.2d 146, 155 (Tex.Crim.App.1990) (emphasis in original).	1	3
Clark v. Stategreen texcrimapp · 2012 · cited in 1 Texas opinions naming this issue, 2026–2026 1 sentence 2026See Clark, 365 S.W.3d at 339 ; Lovill, 319 S.W.3d at 691–92; Pena, 285 S.W.3d at 464 .	1	1
Lasalle Bank National Ass'n v. Whitegreen tex · 2007 · cited in 1 Texas opinions naming this issue, 2025–2025 2 sentences 2025Landry acknowledged that she and her husband lived on the property during the entire course of these events and paid rent at some point, but the 30 See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (“By definition, equitable remedies apply only when there is no remedy at law . . . .”). 31 649 S.W.3d at 197. 32 704 S.W.3d at 33 (quoting Mitchell, 649 S.W.3d at 194). 11 lease proffered as summary judgment evidence is dated August 3, 2009—outside of the two-year limitations period that began to run on February 9, 2007, with the recording of the constable’s deed. 33 Accordingl 2025Landry acknowledged that she and her husband lived on the property during the entire course of these events and paid rent at some point, but the 30 See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (“By definition, equitable remedies apply only when there is no remedy at law . . . .”). 31 649 S.W.3d at 197. 32 704 S.W.3d at 33 (quoting Mitchell, 649 S.W.3d at 194). 11 lease proffered as summary judgment evidence is dated August 3, 2009—outside of the two-year limitations period that began to run on February 9, 2007, with the recording of the constable’s deed. 33 Accordingl	1	1
McNally v. Guevaragreen tex · 2001 · cited in 1 Texas opinions naming this issue, 2014–2014 1 sentence 2014See McNally v. Guevara, 52 S.W.3d 195, 195 (Tex. 2001).	1	1
In Re Houstongreen texapp · 2002 · cited in 1 Texas opinions naming this issue, 2014–2014 1 sentence 2014Cf. Houston, 92 S.W.3d at 873, 877 (concluding language in a motion that merely requested the court “find [relator] in contempt of court” failed to provide notice that criminal contempt was sought).	1	1
Crawford v. Washingtongreen scotus · 2004 · cited in 1 Texas opinions naming this issue, 2012–2012	1	1
Texas Mutual Insurance Co. v. Ruttigergreen tex · 2012 · cited in 1 Texas opinions naming this issue, 2012–2012	1	1
ST. LUKE'S EPISCOPAL HOSPITAL v. Marksgreen tex · 2006 · cited in 1 Texas opinions naming this issue, 2008–2008	1	1
Bozeman v. Kornblitgreen texapp · 2007 · cited in 1 Texas opinions naming this issue, 2008–2008	1	1
Meraz v. Stategreen texcrimapp · 1990 · cited in 1 Texas opinions naming this issue, 1994–1994	1	1
Smiley v. Johnsongreen texapp · 1988 · cited in 1 Texas opinions naming this issue, 1991–1991	1	1
Kennedy v. Upshawgreen · 1886 · cited in 1 Texas opinions naming this issue, 1955–1955	1	1

Distinguished, questioned or overruled (2)

Case	Negative	Cited
Combs v. Stategreen texcrimapp · 1982 · cited in 3 Texas opinions naming this issue, 1987–1994 2 sentences 1994Nevertheless, whether the evidence satisfies the current Jackson test is a "question of law." Combs v. State, 643 S.W.2d 709, 716 (Tex.Crim.App.1982), overruled on other grounds, Butler v. State, 769 S.W.2d 234, 239 (Tex.Crim.App.1989) and Meraz v. State, 785 S.W.2d 146, 155 (Tex.Crim.App.1990) (emphasis in original). 1994Nevertheless, whether the evidence satisfies the current Jackson test is a "question of law." Combs v. State, 643 S.W.2d 709, 716 (Tex.Crim.App.1982), overruled on other grounds, Butler v. State, 769 S.W.2d 234, 239 (Tex.Crim.App.1989) and Meraz v. State, 785 S.W.2d 146, 155 (Tex.Crim.App.1990) (emphasis in original).	2	3
Banks v. Stategreen texcrimapp · 1974 · cited in 2 Texas opinions naming this issue, 1987–1987 2 sentences 1987Nevertheless, in Combs, supra at 716-717 (emphasis in original), this Court read Jackson to be in accord with the “no evidence” standard of Banks, supra, which is identical to the doctrine of Thompson , overruled by the Supreme Court in Jackson : Clearly, the federal constitutional standard is also a question of law and does not involve any weighing of the evidence ... 1987Nevertheless, in Combs, supra at 716-717 (emphasis in original), this Court read Jackson to be in accord with the “no evidence” standard of Banks, supra, which is identical to the doctrine of Thompson , overruled by the Supreme Court in Jackson : Clearly, the federal constitutional standard is also a question of law and does not involve any weighing of the evidence ...	2	2

Also cited on this issue (28)

Case	Cited	Years
Jackson v. Virginia red scotus · 1979 2 sentences 2017The [*2790] Thompson doctrine sible within the fixed bounds of jury considera- simply fails to supply a workable or even a predictable Page 14 443 U.S. 307 , ; 99 S. Ct. 2781 , ; 61 L. 2017The [2790] Thompson doctrine sible within the fixed bounds of jury considera- simply fails to supply a workable or even a predictable Page 14 443 U.S. 307 , ; 99 S. Ct. 2781 , *; 61 L.	3	1989–2017
Stone v. Powell green scotus · 1976 2 sentences 2017In sum, counsel for the State urges that this type of constitutional claim should be [*LEdHR20A] Application of the deemed to fall within the limit on federal habeas corpus Thompson standard to assess the validity of a jurisdiction identified in Stone v. Powell, 428 U.S. 465 , criminal conviction after Winship could lead to with respect to Fourth Amendment claims. 2015**In sum, counsel for the State urges that this type of constitutional claim should be deemed to fall within the limit on federal habeas corpus jurisdiction identified in Stone v. Powell, 428 U.S. 465 , with respect to Fourth Amendment claims.	3	2015–2017
Jacobellis v. Ohio green scotus · 1964 2 sentences 2019Id. (alteration in original) The Supreme Court then concluded, After Winship the critical inquiry on review of the sufficiency of the evidence to support a criminal conviction must be . . . whether the record evidence could reasonably support a finding of guilt beyond a reasonable doubt. . . . [T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the 12 crime beyond a reasonable doubt. 2019Id. (alteration in original) The Supreme Court then concluded, After Winship the critical inquiry on review of the sufficiency of the evidence to support a criminal conviction must be . . . whether the record evidence could reasonably support a finding of guilt beyond a reasonable doubt. . . . [T]he relevant question is whether, after viewing the evidence in the light most favorable to the prosecution, any rational trier of fact could have found the essential elements of the 12 crime beyond a reasonable doubt.	2	1989–2019
Fay v. Noia red scotus · 1963 2 sentences 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U.S. 501 ; Francis v. Henderson, 425 U.S. 536 ; Wainwright v. Sykes, 433 U.S. 72 ; Fay v. Noia, 372 U.S. 391, 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding. 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U. S. 501 ; Francis v. Henderson, 425 U. S. 536 ;Wainwright v. Sykes, 433 U. S. 72 ; Fay v. Noia, 372 U. S. 391 , 372 U. S. 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding.	2	2015–2015
Francis v. Henderson green scotus · 1976 2 sentences 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U.S. 501 ; Francis v. Henderson, 425 U.S. 536 ; Wainwright v. Sykes, 433 U.S. 72 ; Fay v. Noia, 372 U.S. 391, 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding. 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U. S. 501 ; Francis v. Henderson, 425 U. S. 536 ;Wainwright v. Sykes, 433 U. S. 72 ; Fay v. Noia, 372 U. S. 391 , 372 U. S. 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding.	2	2015–2015
Estelle v. Williams green scotus · 1976 2 sentences 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U.S. 501 ; Francis v. Henderson, 425 U.S. 536 ; Wainwright v. Sykes, 433 U.S. 72 ; Fay v. Noia, 372 U.S. 391, 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding. 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U. S. 501 ; Francis v. Henderson, 425 U. S. 536 ;Wainwright v. Sykes, 433 U. S. 72 ; Fay v. Noia, 372 U. S. 391 , 372 U. S. 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding.	2	2015–2015
Wainwright v. Sykes green scotus · 1977 2 sentences 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U.S. 501 ; Francis v. Henderson, 425 U.S. 536 ; Wainwright v. Sykes, 433 U.S. 72 ; Fay v. Noia, 372 U.S. 391, 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding. 2015Thus, assuming that state remedies have been exhausted, see 28 U.S.C. § 2254 (b), and that no independent and adequate state ground stands as a bar, see Estelle v. Williams, 425 U. S. 501 ; Francis v. Henderson, 425 U. S. 536 ;Wainwright v. Sykes, 433 U. S. 72 ; Fay v. Noia, 372 U. S. 391 , 372 U. S. 438 , it follows that such a claim is cognizable in a federal habeas corpus proceeding.	2	2015–2015
Green v. State green texcrimapp · 1986 2 sentences 2015CODE art. 42.08. 47 Thompson’s brief p. 15-17 (citing Green v. State, 706 S.W.2d 653 (Tex. Crim. 2015CODE art. 42.08. 47 Thompson’s brief p. 15-17 (citing Green v. State, 706 S.W.2d 653 (Tex. Crim.	2	2015–2015
Nicholas Jared Mireles v. State green texapp · 2014 2 sentences 2015App. 1986)). 48 Mireles, 444 S.W.3d at 681 -82 (citing Act effective Aug. 31, 1987, 70th Leg., R.S., ch. 513, § 1, 1987 Tex. Gen. 2015App. 1986)). 48 Mireles, 444 S.W.3d at 681 -82 (citing Act effective Aug. 31, 1987, 70th Leg., R.S., ch. 513, § 1, 1987 Tex. Gen.	2	2015–2015
Arizona v. Youngblood green scotus · 1989 2 sentences 2012This situation is governed by the line of cases following Arizona v. Youngblood, 488 U.S. 51 (1988). 2012This situation is governed by the line of cases following Arizona v. Youngblood , 488 U.S. 51 (1988).	2	2012–2012
Watson v. State green texcrimapp · 2006 2 sentences 2007Id. 2007Id.	2	2007–2007
In Re ZLT green texapp · 2002 2 sentences 2003Id. 2003Id.	2	2003–2003
Pena v. State green texcrimapp · 2009 1 sentence 2026See Clark, 365 S.W.3d at 339 ; Lovill, 319 S.W.3d at 691–92; Pena, 285 S.W.3d at 464 .	1	2026–2026
Lovill v. State green texcrimapp · 2009 1 sentence 2026See Clark, 365 S.W.3d at 339 ; Lovill, 319 S.W.3d at 691–92; Pena, 285 S.W.3d at 464 .	1	2026–2026
In the Interest of E.R. green tex · 2012 1 sentence 2025Because the record does not establish the timing of Landry’s notice of Thompson’s claim to the property, the court of 41 649 S.W.3d at 196. 42 Id. at 197. 43 See 385 S.W.3d at 569 . 14 appeals properly remanded Thompson’s equitable defenses for consideration on remand. * * * Notice during the limitations period that property has been sold to satisfy a tax default judgment defeats an action against the purchaser to recover the property brought outside the limitations period.	1	2025–2025
Nix v. State green texcrimapp · 2001 1 sentence 2024This is permissible because “[a] void judgment is a nullity and can be attacked at any time.” Nix v. State, 65 S.W.3d 664 , 667–68 (Tex. Crim.	1	2024–2024
In re Thompson green texapp · 2018 1 sentence 2023In re Thompson, 569 S.W.3d 169 , 172–75 (Tex. App.—Houston [1st Dist.] 2018, orig. proceeding).	1	2023–2023
Larry Webb v. State green texapp · 2018 1 sentence 2020Webb, 557 S.W.3d at 698 .	1	2020–2020
Craddock v. Sunshine Bus Lines, Inc. green tex · 1939 1 sentence 2018Craddock, 133 S.W.2d at 126 .	1	2018–2018
Gerald Mac Lowrey v. State green texapp · 2015 1 sentence 2018For that reason, his complaint was not preserved for our review. 5 See Lowrey, 469 S.W.3d at 327 .	1	2018–2018
Essex Crane Rental Corp. and Vincent A. Morano v. Kenneth Beverly green texapp · 2012 1 sentence 2014There was evidence, including many years’ performance by parties and parties’ predecessors, that supports the trial court’s ruling denying Thompson’s claim for a quiet title. 12 “People can be in privity in at least three ways: (1) they can control an action even if they are not parties to it; (2) their interests can be represented by a party to the action; or (3) they can be successors in interest, deriving their claims through a party to the prior action.” Id. at 652–53.	1	2014–2014
In Re ZLT green tex · 2003	1	2007–2007
Thompson v. Kawasaki Motors Corp. U.S.A. green texapp · 1991	1	1994–1994
Burks v. Madyun green illappct · 1982	1	1992–1992
Collins v. Youngblood green scotus · 1990	1	1991–1991
Proctor v. State green texcrimapp · 1971	1	1984–1984
Park v. Sullivan green texapp · 1928	1	1955–1955
Thompson v. Crim green texapp · 1937	1	1942–1942

Statutes the citing opinions construe

TX § Tex. Penal Code § 1.07 (3) TX § Tex. Penal Code § 22.01 (3) TX § Tex. Penal Code § 30.02 (3) TX § Tex. Penal Code § 31.03 (3) TX § Tex. Penal Code § 38.04 (3) TX § Tex. Penal Code § 43.26 (3) USC § 18u.s.c.2 (3) USC § 26u.s.c.5861 (3) USC § 28u.s.c.2254 (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

TX 47 (1942–2026) CA 37 (1971–2025) OH 26 (1990–2026) WA 24 (1996–2026) PA 23 (1985–2025) GA 23 (1987–2026) FL 22 (1985–2019) IL 20 (1978–2026) IA 18 (1992–2025) AL 14 (1985–2025) MS 11 (1979–2025) IN 10 (1999–2020) KS 8 (1973–2025) AR 8 (1979–2025) MI 8 (1902–2025) OR 7 (1995–2025) MD 7 (1987–2021) AZ 7 (1968–2022) ND 6 (1985–2011) SC 6 (2003–2019) ME 6 (1977–2022) DC 6 (1983–2016) MO 5 (1995–2025) NE 5 (1990–2023) MN 4 (1985–2016) NY 4 (1984–2011) VA 4 (1997–2023) WI 4 (1987–2023) UT 4 (2014–2025) DE 4 (1982–2026) ID 4 (1992–2016) CT 3 (2004–2010) MT 3 (1934–2015) VT 3 (2011–2024) NC 3 (1990–2014) CO 2 (2001–2021) WV 2 (2010–2017) SD 2 (1985–1997) TN 2 (1999–2004) KY 2 (1914–2000) OK 2 (2010–2015) NJ 2 (1971–2005)

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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