immediately preceding clause in Texas

2026In her concurrence, Chief Justice Contreras stated that although the charge tracked the statute “precisely,” the statutory language was insufficient because it “did not explicitly inform the jury that there must be ‘at least 28 days’ between the days of the first and last acts of abuse.” Id. at 383; see Turner, 573 S.W.3d at 462 (determining that charge requiring two or more acts of sexual abuse “on or about June 1, 2013 through August 1, 2013, . . . during a period 26 that was 30 days or more in duration” was erroneous because it did not “make it clear that the first and last acts must occur

2024We disagree with any suggestion that delineating the period of continuous abuse with specific dates that were themselves more than thirty days apart somehow nullified the abstract portion of the charge or the immediately preceding requirement in the application paragraph that Perez committed two or more acts of sexual abuse “during a period that was 30 or more days in duration.” See id.; Lewis v. State, No. 14-21-00691-CR, 2023 WL 4873306 , at *7 (Tex. App.— Houston [14th Dist.] Aug. 1, 2023, pet. ref’d) (finding no jury charge error where the trial court used similar language in the applicati

2026In her concurrence, Chief Justice Contreras stated that although the charge tracked the statute “precisely,” the statutory language was insufficient because it “did not explicitly inform the jury that there must be ‘at least 28 days’ between the days of the first and last acts of abuse.” Id. at 383; see Turner, 573 S.W.3d at 462 (determining that charge requiring two or more acts of sexual abuse “on or about June 1, 2013 through August 1, 2013, . . . during a period 26 that was 30 days or more in duration” was erroneous because it did not “make it clear that the first and last acts must occur

2020See id. at 641 (holding so with respect to term “real property”); see also Erwin v. Steele, 228 S.W.2d 882, 886 (Tex. App.—Dallas 1950, writ ref’d n.r.e.) (bequest of “personal property” includes “every form of personal property from whatever source it may be derived; that is, everything except real property”). 6 Analysis We must decide whether Hunt’s bequest to Vargas of “all my remaining household and personal property” conveys all of Hunt’s personal property other than the family-related items she gave to Mitchell in the immediately preceding clause of the will or conveys a more limited sub

2020See id. at 641 (holding so with respect to term “real property”); see also Erwin v. Steele, 228 S.W.2d 882, 886 (Tex. App.—Dallas 1950, writ ref’d n.r.e.) (bequest of “personal property” includes “every form of personal property from whatever source it may be derived; that is, everything except real property”). 6 Analysis We must decide whether Hunt’s bequest to Vargas of “all my remaining household and personal property” conveys all of Hunt’s personal property other than the family-related items she gave to Mitchell in the immediately preceding clause of the will or conveys a more limited sub

2015Oaks Hosp., LP v. Williams, 371 S.W.3d 171, 185 (Tex.2012) (applying last antecedent rule to a statute' because otherwise the “construction is nonsensical”) (citing 82 C.J.S.

2015Goebel next argues that, under the doctrine of last antecedent, the phrase “sole and absolute discretion” applies only to the immediately preceding clause, “may enter into one or more Sales Contracts in the future,” and not to the clause “may amend such Existing Sales Contracts.” The doctrine of last antecedent is neither controlling nor inflexible and is not applicable when “further extension is clearly required by the intent and meaning of the context.” See City of Corsicana v. Willmann, 147 Tex. 377 , 216 S.W.2d 175, 176 (1949) (last antecedent rule should not be applied without regard to m

2015Goebel next argues that, under the doctrine of last antecedent, the phrase “sole and absolute discretion” applies only to the immediately preceding clause, “may enter into one or more Sales Contracts in the future,” and not to the clause “may amend such Existing Sales Contracts.” The doctrine of last antecedent is neither controlling nor inflexible and is not applicable when “further extension is clearly required by the intent and meaning of the context.” See City of Corsicana v. Willmann, 147 Tex. 377 , 216 S.W.2d 175, 176 (1949) (last antecedent rule should not be applied without regard to m

1997“It articulated, in mandatory language, the concepts of comity and full faith and credit, found in the immediately preceding clause of article IV_ In the administration of justice, ... national unity was thought to be served by de-emphasizing state lines for certain purposes, without impinging on essential state autonomy.” Michigan v. Doran, 439 U.S. 282, 287-88, 99 S.Ct. 530, 534-35 , 58 L.Ed.2d 521 (1978).

1997“It articulated, in mandatory language, the concepts of comity and full faith and credit, found in the immediately preceding clause of article IV_ In the administration of justice, ... national unity was thought to be served by de-emphasizing state lines for certain purposes, without impinging on essential state autonomy.” Michigan v. Doran, 439 U.S. 282, 287-88, 99 S.Ct. 530, 534-35 , 58 L.Ed.2d 521 (1978).