46 Texas opinions name it 4 courts 1956–2026 7 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.
| Case | Followed | Cited |
|---|---|---|
Benedict G. Wenske and Elizabeth Wenske v. Steve Ealy and Deborah Ealygreen2 sentences2026Wenske v. Ealy, 521 S.W.3d 791, 794 (Tex. 2017) (citing Luckel, 819 S.W.2d at 461 ). 2023Wenske v. Ealy, 521 S.W.3d 791, 794 (Tex. 2017) (citing Luckel, 819 S.W.2d at 461 ). | 6 | 6 |
Luckel v. Whitegreen2 sentences2015The “primary duty of a court when construing such a deed is to ascertain the intent of the parties from all of the language in the deed by a fundamental rule of construction known as the four corners rule.” Luckel v. White, 819 S.W.2d 459, 462 (Tex. 1991). 2015Texas Courts apply the four corners rule, Luckel, 819 S.W.2d at 462 , and generally attempt to harmonize provisions in the deed that, at first, appear at odds 10 with each other. | 5 | 21 |
Leggett v. Stategreen2 sentences2013Hankins v. State, 132 S.W.3d 380, 388 (Tex. Crim. 2006Hankins v. State, 132 S.W.3d 380, 388-89 (Tex.Crim.App.2004) (holding that there were insufficient facts within the "four comers" of the affidavit to establish probable cause); see also State v. Colon, 230 Conn. 24 , 644 A.2d 877, 882-883 (1994) (rejecting defendant's claim that "the four corners rule" that applies to the determination of probable cause in a search warrant also applies to the signing of the jurat; magistrate’s failure to sign the warrant jurat did not invalidate the warrant; concluding that “although it is preferable that every affidavit contain a completed jurat, the omission | 4 | 4 |
Bowie Memorial Hospital v. Wrightgreen2 sentences2015When evaluating the report, the court must not fill gaps or draw inferences with respect to opinions or qualification.7 Scoresby, 346 S.W.3d at 556 ; Wright, 79 S.W.3d at 53 ; Palacios, 46 S.W.3d at 878 (“… the only information relevant to the inquiry is within the four corners of the report.”); Austin Heart, P.A., 228 S.W.3d at 279 (the four corners rule “precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended to say.”); Ly v. 7 Reports should not be construed in favor of the claimant. 2009See Bowie Mem’l Hosp., 79 S.W.3d at 52 . | 3 | 4 |
Austin Heart, P.A. v. Webbgreen2 sentences2019The four-corners requirement “precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended.” Austin Heart, P.A. v. Webb, 228 S.W.3d 276, 279 (Tex. App.—Austin 2007, no pet.); see Gray, 189 S.W.3d at 859 . 2018The four-corners requirement nevertheless “precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended.” Austin Heart, 228 S.W.3d at 279 . | 2 | 3 |
Smith v. Stategreen2 sentences2011The four corners rule “applies only to the assessment of probable cause.” See Smith v. State, 207 S.W.3d 787, 794 (Tex. Crim. 2011The four corners rule “applies only to the assessment of probable cause.” See Smith v. State, 207 S.W.3d 787, 794 (Tex. Crim. | 2 | 3 |
American Transitional Care Centers of Texas, Inc. v. Palaciosgreen2 sentences2015When evaluating the report, the court must not fill gaps or draw inferences with respect to opinions or qualification.7 Scoresby, 346 S.W.3d at 556 ; Wright, 79 S.W.3d at 53 ; Palacios, 46 S.W.3d at 878 (“… the only information relevant to the inquiry is within the four corners of the report.”); Austin Heart, P.A., 228 S.W.3d at 279 (the four corners rule “precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended to say.”); Ly v. 7 Reports should not be construed in favor of the claimant. 2005See Palacios , 46 S.W.3d at 878 . | 2 | 2 |
Garrett v. Dils Companygreen2 sentences2015The four-corners rule is a “fundamental rule of construction.” Bennett, 894 S.W.2d at 446 ; see Garrett v. Dils Co., 157 Tex. 92, 94-95 , 299 S.W.2d 904, 906 (1957). 2015The four-corners rule is a “fundamental rule of construction.” Bennett, 894 S.W.2d at 446 ; see Garrett v. Dils Co., 157 Tex. 92, 94-95 , 299 S.W.2d 904, 906 (1957). | 2 | 2 |
Bogar v. Esparzagreen2 sentences2009See Bogar v. Esparza , 257 S.W.3d 354, 362 (Tex. App.--Austin 2008, no pet.) (The four corners requirement "precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended."). 2009See Bogar v. Esparza, 257 S.W.3d 354, 362 (Tex. App.—Austin 2008, no pet.) (The four corners requirement "precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended."). | 2 | 2 |
Coghill v. Griffithgreen2 sentences2014Id. at 840 . 2014Id. at 840. | 1 | 2 |
Schlittler v. Smithgreen1 sentence2025Plainsman Trading Co. v. Crews, 898 S.W.2d 786, 789 (Tex. 1995); Schlittler v. Smith, 101 S.W.2d 543, 544 (Tex. [Comm’n Op.] 1937). | 1 | 1 |
Plainsman Trading Co. v. Crewsgreen1 sentence2025Plainsman Trading Co. v. Crews, 898 S.W.2d 786, 789 (Tex. 1995); Schlittler v. Smith, 101 S.W.2d 543, 544 (Tex. [Comm’n Op.] 1937). | 1 | 1 |
Gray v. CHCA Bayshore L.P.green1 sentence2019The four-corners requirement “precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended.” Austin Heart, P.A. v. Webb, 228 S.W.3d 276, 279 (Tex. App.—Austin 2007, no pet.); see Gray, 189 S.W.3d at 859 . | 1 | 1 |
Hausser v. Cuellargreen2 sentences2018Graham v. Prochaska, 429 S.W.3d 650, 655 (Tex. App.—San Antonio 2013, pet. denied) (citing Luckel v. White, 819 S.W.2d 459, 461 (Tex. 1991)); Hausser v. Cuellar, 345 S.W.3d 462, 466 (Tex. App.—San Antonio 2011, pet. denied) (en banc) (same). 2018See Graham, 429 S.W.3d at 655 ; Hausser, 345 S.W.3d at 466 . | 1 | 1 |
Graham v. Prochaskagreen2 sentences2018Graham v. Prochaska, 429 S.W.3d 650, 655 (Tex. App.—San Antonio 2013, pet. denied) (citing Luckel v. White, 819 S.W.2d 459, 461 (Tex. 1991)); Hausser v. Cuellar, 345 S.W.3d 462, 466 (Tex. App.—San Antonio 2011, pet. denied) (en banc) (same). 2018See Graham, 429 S.W.3d at 655 ; Hausser, 345 S.W.3d at 466 . | 1 | 1 |
Anadarko Petroleum Corp. v. Thompsongreen1 sentence2015Appellees then ask this Court to rely solely on the phrase “consisting of one-half of the royalty interest now owned by” 1 See, e.g., Anadarko Petroleum Corp. v. Thompson, 94 S.W.3d 550, 554 (Tex. 2002) (explaining the application of the four corners rule with regard to an oil and gas lease and providing that, “We examine the entire lease and attempt to harmonize all its parts, even if different parts appear contradictory or inconsistent. | 1 | 1 |
Hancock v. Butlergreen1 sentence2015Frost Nat’l Bank v. L & F Distribs, Ltd., 165 S.W.3d, 311 -12 (Tex. 2005); Hancock v. Butler, 21 Tex. 804, 806 (1858). | 1 | 1 |
State v. Colongreen2 sentences2006Hankins v. State, 132 S.W.3d 380, 388-89 (Tex.Crim.App.2004) (holding that there were insufficient facts within the "four comers" of the affidavit to establish probable cause); see also State v. Colon, 230 Conn. 24 , 644 A.2d 877, 882-883 (1994) (rejecting defendant's claim that "the four corners rule" that applies to the determination of probable cause in a search warrant also applies to the signing of the jurat; magistrate’s failure to sign the warrant jurat did not invalidate the warrant; concluding that “although it is preferable that every affidavit contain a completed jurat, the omission 2006Hankins v. State, 132 S.W.3d 380, 388-89 (Tex.Crim.App.2004) (holding that there were insufficient facts within the "four comers" of the affidavit to establish probable cause); see also State v. Colon, 230 Conn. 24 , 644 A.2d 877, 882-883 (1994) (rejecting defendant's claim that "the four corners rule" that applies to the determination of probable cause in a search warrant also applies to the signing of the jurat; magistrate’s failure to sign the warrant jurat did not invalidate the warrant; concluding that “although it is preferable that every affidavit contain a completed jurat, the omission | 1 | 1 |
Concord Oil Co. v. Pennzoil Exploration and Production Co.green1 sentence2005Concord Oil Company v. Pennzoil Exploration and Production Company, 966 S.W.2d 451, 465 (Tex.1998). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Kosanda v. State
green
2 sentences2012Thus, we seem to have at least implicitly rejected application of the four-corners rule to the face of the warrant itself, having resorted to other record facts to declare the warrant validly "issued." [46] 727 S.W.2d 783 (Tex.App.-Dallas 1987, pet. ref'd). [47] Id. at 784 . [48] Id. [49] Id. [50] Id. at 785 . [1] Tex.Code Crim. 2012Thus, we seem to have at least implicitly rejected application of the four-corners rule to the face of the warrant itself, having resorted to other record facts to declare the warrant validly "issued." [46] 727 S.W.2d 783 (Tex.App.-Dallas 1987, pet. ref'd). [47] Id. at 784 . [48] Id. [49] Id. [50] Id. at 785 . [1] Tex.Code Crim. | 3 | 2012–2012 |
French v. Chevron U.S.A. Inc.
green
2 sentences2014French, 896 S.W.2d at 797 (citing Luckel, 819 S.W.2d at 461 ) (emphasis added). 2013French, 896 S.W.2d at 797 (citing Luckel, 819 S.W.2d at 461 ) (emphasis added). | 2 | 2013–2014 |
Lambright v. Texas Parks & Wildlife Department
green
1 sentence2025Lambright, 157 S.W.3d at 504 . | 1 | 2025–2025 |
Columbia Valley Healthcare System, L.P. D/B/A Valley Regional Medical Center v. Maria Zamarripa, as Guardian of the Estates of R.F.R. and R.J.R., Minors
green
1 sentence2018A report is adequate with respect to causation if it explains, “based on facts set out in the report, how and why a health care provider’s breach of the standard of care caused the injury.” Zamarripa, 526 S.W.3d at 459–60 (citation and punctuation marks omitted). | 1 | 2018–2018 |
Blake v. State
green
2 sentences2015Blake v. State, 125 S.W.3d 717 (Tex. App. – Houston [1st Dist.] 2003 no pet.) gives a concise recitation of case law and principles concerning the analysis of suppression questions on appeal: reviewed under an abuse of discretion, the four corners doctrine, probable cause, reliability of the informant. 2015There it was stated that the reliability of the informant should be based upon the assertion that “that the informant had given information in the past regarding narcotics trafficking which had proved correct” Id., at 726 . | 1 | 2015–2015 |
Cardona v. State
green
1 sentence2015Id. | 1 | 2015–2015 |
Bennett v. TARRANT CTY WATER CONTROL
green
1 sentence2015The four-corners rule is a “fundamental rule of construction.” Bennett, 894 S.W.2d at 446 ; see Garrett v. Dils Co., 157 Tex. 92, 94-95 , 299 S.W.2d 904, 906 (1957). | 1 | 2015–2015 |
Tyler Scoresby, M.D. v. Catarino Santillan, Individually and as Next Friend of Samuel Santillan, a Minor
green
1 sentence2015When evaluating the report, the court must not fill gaps or draw inferences with respect to opinions or qualification.7 Scoresby, 346 S.W.3d at 556 ; Wright, 79 S.W.3d at 53 ; Palacios, 46 S.W.3d at 878 (“… the only information relevant to the inquiry is within the four corners of the report.”); Austin Heart, P.A., 228 S.W.3d at 279 (the four corners rule “precludes a court from filling gaps in a report by drawing inferences or guessing as to what the expert likely meant or intended to say.”); Ly v. 7 Reports should not be construed in favor of the claimant. | 1 | 2015–2015 |
Alford v. Krum
red
2 sentences2011In Luckel , the Court overruled its earlier opinion in Alford v. Krum, 671 S.W.2d 870 (Tex.1984) on the grounds that the Alford majority “failed to harmonize the provisions under the four corners rule and then erred in applying the ‘repugnant to the grant’ rule in disregard of the future lease clause.” Luckel, 819 S.W.2d at 464 . 1 The Luckel Court held that a court’s primary duty “when construing such a deed is to ascertain the intent of the parties from all of the language in the deed by a fundamental rule of construction known as the ‘four corners’ rule.” Id. at 461 . 2011In Luckel , the Court overruled its earlier opinion in Alford v. Krum, 671 S.W.2d 870 (Tex.1984) on the grounds that the Alford majority "failed to harmonize the provisions under the four corners rule and then erred in applying the `repugnant to the grant' rule in disregard of the future lease clause." Luckel, 819 S.W.2d at 464 . [1] The Luckel Court held that a court's primary duty "when construing such a deed is to ascertain the intent of the parties from all of the language in the deed by a fundamental rule of construction known as the `four corners' rule." Id. at 461 . | 1 | 2011–2011 |
Franks v. Delaware
green
2 sentences2010The Supreme Court held in Franks v. Delaware, 438 U.S. 154 , 98 S. Ct. 2674 , 57 L. 2010The Supreme Court held in Franks v. Delaware, 438 U.S. 154 , 98 S. Ct. 2674 , 57 L. | 1 | 2010–2010 |
Seaboard Surety Co. v. Racine Screw Co.
green
1 sentence1956Under what,circumstances the motion should be granted then becomes a separate inquiry.” Appellant .has primarily relied on the case of Seaboard Surety Co. v. Racine *839 Screw Co., 7 Cir., 203 F.2d 532, 534 , wherein Federal Rule 56 was construed as he would have ús construe Texas Rule 166-A. It was held that a summary judgment decreeing specific performance of a contract was not authorized by Federal Rule 56, 28 U.S.C.A., the court saying, in part: It is our view that the rule was not intended to, and from its phraseology does not encompass a situation wherein the relief sought is not allowab | 1 | 1956–1956 |
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.
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.