purely procedural error (Texas) · Go Syfert
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purely procedural error in Texas

6 Texas opinions name it 1 courts 2010–2024 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 (4)

CaseFollowedCited
Few v. Stategreen
texcrimapp · 2007 · cited in 4 Texas opinions naming this issue, 2010–2023
2 sentences

2023See Few, 230 S.W.3d at 188–190; Pena v. State, 323 S.W.3d 522, 526 (Tex. App.—Corpus Christi–Edinburg 2010, no pet.) (“Dismissal for an incorrect cause number, unlike a defective certification where there is no underlying right of appeal, bars an appeal based on a purely procedural error, rather than a substantive restriction.”); see also Ex parte Espinoza, No. 02-15- 00074-CR, 2015 WL 1967230 , at *1 (Tex. App.—Fort Worth Apr. 30, 2015, pet. ref’d) (mem. op., not designated for publication) (assigning sua sponte a criminal cause number on appeal where the trial court clerk had mistakenly assi

2010See id. at 189 (“[O]ur appellate rules ... disfavor() disposing of appeals based upon harmless procedural defects.”).

44
Pena v. Stategreen
texapp · 2010 · cited in 2 Texas opinions naming this issue, 2023–2024
2 sentences

2024App. 2007); see also Pena v. State, 323 S.W.3d 522, 526 (Tex. App.—Corpus Christi–Edinburg 2010, no pet.) (“Dismissal for an incorrect cause number, unlike a defective certification where there is no underlying right of appeal, bars an appeal based on a purely procedural error, rather than a substantive restriction.”). 10 certification of the defendant’s right to appeal in which the court certified that this is not a plea bargain case and the defendant has the right of appeal, . . . [t]he trial court’s erroneous certification does not constitute permission to appeal”); Pena v. State, 323 S.W.3

2024App. 2007); see also Pena v. State, 323 S.W.3d 522, 526 (Tex. App.—Corpus Christi–Edinburg 2010, no pet.) (“Dismissal for an incorrect cause number, unlike a defective certification where there is no underlying right of appeal, bars an appeal based on a purely procedural error, rather than a substantive restriction.”). 10 certification of the defendant’s right to appeal in which the court certified that this is not a plea bargain case and the defendant has the right of appeal, . . . [t]he trial court’s erroneous certification does not constitute permission to appeal”); Pena v. State, 323 S.W.3

22
Waters v. Stategreen
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024App. 2007); see also Pena v. State, 323 S.W.3d 522, 526 (Tex. App.—Corpus Christi–Edinburg 2010, no pet.) (“Dismissal for an incorrect cause number, unlike a defective certification where there is no underlying right of appeal, bars an appeal based on a purely procedural error, rather than a substantive restriction.”). 10 certification of the defendant’s right to appeal in which the court certified that this is not a plea bargain case and the defendant has the right of appeal, . . . [t]he trial court’s erroneous certification does not constitute permission to appeal”); Pena v. State, 323 S.W.3

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

2024App. 2007); see also Pena v. State, 323 S.W.3d 522, 526 (Tex. App.—Corpus Christi–Edinburg 2010, no pet.) (“Dismissal for an incorrect cause number, unlike a defective certification where there is no underlying right of appeal, bars an appeal based on a purely procedural error, rather than a substantive restriction.”). 10 certification of the defendant’s right to appeal in which the court certified that this is not a plea bargain case and the defendant has the right of appeal, . . . [t]he trial court’s erroneous certification does not constitute permission to appeal”); Pena v. State, 323 S.W.3

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Distinguished, questioned or overruled (1)

CaseNegativeCited
Menjivar v. Stategreen
texapp · 2007 · cited in 1 Texas opinions naming this issue, 2024–2024
1 sentence

2024But see Menjivar v. State, 264 S.W.3d 137, 142 (Tex. App.—Houston [1st Dist.] 2007, no pet.) (“[W]hen the certification is defective by stating that a right of appeal exists where the 11 record affirmatively shows no right of appeal, we must . . . order the trial court to amend the certification to correct the defect in the certification.”).

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Also cited on this issue (3)

CaseCitedYears
Ajagbe v. State green
texapp · 2004
1 sentence

2024App. 2007); see also Pena v. State, 323 S.W.3d 522, 526 (Tex. App.—Corpus Christi–Edinburg 2010, no pet.) (“Dismissal for an incorrect cause number, unlike a defective certification where there is no underlying right of appeal, bars an appeal based on a purely procedural error, rather than a substantive restriction.”). 10 certification of the defendant’s right to appeal in which the court certified that this is not a plea bargain case and the defendant has the right of appeal, . . . [t]he trial court’s erroneous certification does not constitute permission to appeal”); Pena v. State, 323 S.W.3

12024–2024
Howsam v. Dean Witter Reynolds, Inc. green
scotus · 2002
1 sentence

2019As a result, the Court held that satisfaction of the condition was for the arbitrators to decide, not the courts, because parties “normally expect a forum-based decision-maker to decide forum-specific procedural gateway matters.” Id. at 34- 35, quoting Howsam, 537 U.S. at 86 .10 Our supreme court adopted this same view in G.T.

12019–2019
BG Group, PLC v. Republic of Argentina green
scotus · 2014
2 sentences

2019Id. at 35- 36 (“The litigation provision is consequently a purely procedural requirement--a claims-processing 22 rule that governs when the arbitration may begin, but not whether it may occur or what its substantive outcome will be on the issues in dispute.”).

2019As a result, the Court held that satisfaction of the condition was for the arbitrators to decide, not the courts, because parties “normally expect a forum-based decision-maker to decide forum-specific procedural gateway matters.” Id. at 34- 35, quoting Howsam, 537 U.S. at 86 .10 Our supreme court adopted this same view in G.T.

12019–2019

Where else courts name it

TX 6 (2010–2024) NM 3 (1985–2001) CA 2 (2014–2022) NV 2 (2016–2016)

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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