opportunity to cure error (Texas) · Go Syfert
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opportunity to cure error in Texas

45 Texas opinions name it 3 courts 1988–2023 3 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 (19)

CaseFollowedCited
Hollins v. Stategreen
texcrimapp · 1991 · cited in 12 Texas opinions naming this issue, 1993–2022
2 sentences

2022“The purpose of a timely objection is to give the trial judge the opportunity to cure error.” Hollins v. State, 805 S.W.2d 475, 476 (Tex. Crim.

2015A. Preservation of Error “The purpose of a timely objection is to give the trial judge the opportunity to cure error.” Hollins v. State, 805 S.W.2d 475, 476 (Tex. Crim.

812
Lake v. Premier Transportationgreen
texapp · 2008 · cited in 5 Texas opinions naming this issue, 2012–2023
2 sentences

2014See Tryco Enters., Inc. v. Robinson, 390 S.W.3d 497, 505 (Tex.App.-Houston [1st Dist.] 2012, pet. dism’d) (stating, in context of Rule of Appellate Procedure 33.1 and Rule of Evidence 103, that “the party must have made a timely, specific objection at the earliest possible opportunity”); Lake v. Premier Transp., 246 S.W.3d 167, 174 (Tex.App.-Tyler 2007, no pet.) (“To be considered timely, an objection must be specific enough to enable the trial court to understand the precise nature of the error alleged and interposed at such a point in the proceedings so as to enable the trial court the oppor

2012Co., 772 S.W.2d 72, 74 (Tex. 1989) (stating that specific objection enables trial court to understand precise grounds and make informed ruling and affords offering party opportunity to remedy defect, if possible); Lake v. Premier Transp., 246 S.W.3d 167, 174 (Tex.App.Tyler 2007, no pet.) (observing that specific and timely objection is necessary to preserve argument for appellate review and stating, “To be considered timely, an objection must be specific enough to enable the trial court to understand the precise nature of the error alleged and interposed at such a point in the proceedings so a

55
Anderson v. Stategreen
texcrimapp · 1982 · cited in 5 Texas opinions naming this issue, 1988–2018
2 sentences

2018Hollins, 805 S.W.2d at 476 (citing Anderson v. State, 633 S.W.2d 851 (Tex.Crim.App. 1982)).

2015See generally Anderson v. State, 633 S.W.2d 851 (Tex. Crim.

45
Cockrell v. Stategreen
texcrimapp · 1996 · cited in 4 Texas opinions naming this issue, 2003–2007
2 sentences

2007See Cockrell v. State , 933 S.W.2d 73, 89 (Tex.Crim.App. 1996).

2003See Cockrell v. State , 933 S.W.2d 73, 89 (Tex.Crim.App. 1996).

44
In Re JGgreen
texapp · 2006 · cited in 3 Texas opinions naming this issue, 2014–2015
2 sentences

2015App. 1991); In re J.G., 195 S.W.3d 161, 177 (Tex. App.—San Antonio 2006, no pet.).

2015App. 1991); In re J.G., 195 S.W.3d 161, 177 (Tex. App.—San Antonio 2006, no pet.).

33
McKinney v. National Union Fire Insurance Co. of Pittsburghgreen
tex · 1989 · cited in 2 Texas opinions naming this issue, 2012–2012
2 sentences

2012Co., 772 S.W.2d 72, 74 (Tex. 1989) (stating that specific objection enables trial court to understand precise grounds and make informed ruling and affords offering party opportunity to remedy defect, if possible); Lake v. Premier Transp., 246 S.W.3d 167, 174 (Tex. App.—Tyler 2007, no pet.) (observing that specific and timely objection is necessary to preserve argument for appellate review and stating, “To be considered timely, an objection must be specific enough to enable the trial court to understand the precise nature of the error alleged and interposed at such a point in the 11 proceedings

2012Co., 772 S.W.2d 72, 74 (Tex. 1989) (stating that specific objection enables trial court to understand precise grounds and make informed ruling and affords offering party opportunity to remedy defect, if possible); Lake v. Premier Transp., 246 S.W.3d 167, 174 (Tex.App.Tyler 2007, no pet.) (observing that specific and timely objection is necessary to preserve argument for appellate review and stating, “To be considered timely, an objection must be specific enough to enable the trial court to understand the precise nature of the error alleged and interposed at such a point in the proceedings so a

22
Warwick Towers Council of Co-Owners Ex Rel. St. Paul Fire & Marine Insurance Co. v. Park Warwick L.P.green
tex · 2008 · cited in 2 Texas opinions naming this issue, 2009–2009
2 sentences

2009The supreme court has instructed us to liberally construe the rules in favor of preserving the right to appeal of a party who makes a bona fide (1) attempt to invoke our jurisdiction, id. at 616 , and to give an appellant the opportunity to cure error when possible in favor of reaching the merits of an appeal, Warwick Towers Council of Co-Owners v. Park Warwick, L.P. , 244 S.W.3d 838, 839 (Tex. 2008) (quoting Grand Prairie Indep.

2009The supreme court has instructed us to liberally construe the rules in favor of preserving the right to appeal of a party who makes a bona fide1 attempt to invoke our jurisdiction, id. at 616 , and to give an appellant the opportunity to cure error when possible in favor of reaching the merits of an appeal, Warwick Towers Council of Co-Owners v. Park Warwick, L.P., 244 S.W.3d 838, 839 (Tex. 2008) (quoting Grand Prairie Indep.

22
Elliott v. KRAFT FOODS NORTH AMERICA, INC.green
texapp · 2003 · cited in 2 Texas opinions naming this issue, 2007–2007
2 sentences

2007See, e.g. , Elliott v. Kraft Foods N. Am., Inc. , 118 S.W.3d 50, 56 (Tex. App.--Houston [14th Dist.] 2003, no pet.) ("The proper remedy for a trial court's refusal to file findings of fact and conclusions of law is abatement of an appeal, thereby giving the trial court an opportunity to cure its error.").

2007“The proper remedy for a trial court’s” failure “to file findings of fact and conclusions of law is abatement of an appeal, thereby giving the trial court an opportunity to cure its error.” Elliott v. Kraft Foods N. Am., Inc., 118 S.W.3d 50, 56 (Tex. App.—Houston [14th Dist.] 2003, no pet.); see Tex. R.

22
Torres v. Stategreen
texcrimapp · 1973 · cited in 2 Texas opinions naming this issue, 2003–2003
2 sentences

2003See Torres v. State , 491 S.W.2d 126, 128 (Tex. Crim.

2003See Torres v. State, 491 S.W.2d 126, 128 (Tex. Crim.

22
Beall v. Ditmoregreen
texapp · 1993 · cited in 2 Texas opinions naming this issue, 1995–2008
2 sentences

1995As explained by then-justice and now Chief Justice Barajas in Beall, “ ‘[tjimeliness’ defies definition,” but “it is clear from a simple reading of Texas law, that objections, in order to be considered timely, must be ... interposed at such a point in the proceedings so as to enable the trial court the opportunity to cure the error alleged, if any.” Beall, 867 S.W.2d at 795 .

1995As explained by then-Justice and now Chief Justice Barajas in Beall , "`[t]imeliness' defies definition," but "it is clear from a simple reading of Texas law, that objections, in order to be considered timely, must be ... interposed at such a point in the proceedings so as to enable the trial court the opportunity to cure the error alleged, if any." Beall, 867 S.W.2d at 795 .

12
Trevino v. Stategreen
texapp · 2005 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Trevino v. State, 174 S.W.3d 925, 927 (Tex. App.—Corpus Christi 2005, pet. ref’d) (citing Smith v. State, 721 S.W.2d 844, 855 (Tex. Crim.

11
Nagakrishna Reddy, M.D. And New Braunfels Ob/Gyn, P.A. v. Haley Hebner and Darrin Charles Scott, Individually and as Next Friends of R. M. S., a Minorgreen
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Id. at 337-42 (Pemberton, J., dissenting).

11
Peter John Schuster v. Stategreen
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Hollins, 805 S.W.2d at 476 ; Schuster v. State, 435 S.W.3d 362, 366 (Tex. App.--Houston [1st Dist.] 2014, no pet.).

11
Smith v. Stategreen
texcrimapp · 1986 · cited in 1 Texas opinions naming this issue, 2015–2015
1 sentence

2015Trevino v. State, 174 S.W.3d 925, 927 (Tex. App.—Corpus Christi 2005, pet. ref’d) (citing Smith v. State, 721 S.W.2d 844, 855 (Tex. Crim.

11
Bush v. Bushgreen
texapp · 2010 · cited in 1 Texas opinions naming this issue, 2014–2014
1 sentence

2014See Bush, 336 S.W.3d at 728-29 (holding that objection to scope of amicus attorney’s appointment made in motion for new trial filed more than eighteen months after court appointed amicus attorney failed to preserve complaint for appeal); cf. Suttles v. Vestin Realty Mortg.

11
Tryco Enterprises Inc., Sharon C. Dixon, James Dixon, Crown Staffing, Inc. and Troy Keith Dixon v. James A. Robinsongreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2014–2014
2 sentences

2014See Tryco Enters., Inc. v. Robinson, 390 S.W.3d 497, 505 (Tex.App.-Houston [1st Dist.] 2012, pet. dism’d) (stating, in context of Rule of Appellate Procedure 33.1 and Rule of Evidence 103, that “the party must have made a timely, specific objection at the earliest possible opportunity”); Lake v. Premier Transp., 246 S.W.3d 167, 174 (Tex.App.-Tyler 2007, no pet.) (“To be considered timely, an objection must be specific enough to enable the trial court to understand the precise nature of the error alleged and interposed at such a point in the proceedings so as to enable the trial court the oppor

2014See Tryco Enters., Inc. v. Robinson, 390 S.W.3d 497, 505 (Tex.App.-Houston [1st Dist.] 2012, pet. dism’d) (stating, in context of Rule of Appellate Procedure 33.1 and Rule of Evidence 103, that “the party must have made a timely, specific objection at the earliest possible opportunity”); Lake v. Premier Transp., 246 S.W.3d 167, 174 (Tex.App.-Tyler 2007, no pet.) (“To be considered timely, an objection must be specific enough to enable the trial court to understand the precise nature of the error alleged and interposed at such a point in the proceedings so as to enable the trial court the oppor

11
Shelton v. Stategreen
texcrimapp · 1969 · cited in 1 Texas opinions naming this issue, 2003–2003
1 sentence

2003Shelton v. State , 441 S.W.2d 536, 538 (Tex. Crim.

11
State v. Evansgreen
texcrimapp · 1992 · cited in 1 Texas opinions naming this issue, 1998–1998
1 sentence

1998See State v. Evans, 843 S.W.2d 576 (Tex.Crim.

11
El-Kareh v. Texas Alcoholic Beverage Commissiongreen
texapp · 1994 · cited in 1 Texas opinions naming this issue, 1996–1996
1 sentence

1996El-Kareh v. Texas Alcoholic Beverage Comm’n, 874 S.W.2d 192, 196 (Tex. App. — Houston [14th Dist.] 1994, no writ).

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 (5)

CaseCitedYears
Almanza v. State green
texcrimapp · 1985
2 sentences

2008Almanza , 686 S.W.2d at 157 .

2008Almanza , 686 S.W.2d at 157 .

42008–2008
Verburgt v. Dorner green
tex · 1998
2 sentences

2009The supreme court has instructed us to liberally construe the rules in favor of preserving the right to appeal of a party who makes a bona fide (1) attempt to invoke our jurisdiction, id. at 616 , and to give an appellant the opportunity to cure error when possible in favor of reaching the merits of an appeal, Warwick Towers Council of Co-Owners v. Park Warwick, L.P. , 244 S.W.3d 838, 839 (Tex. 2008) (quoting Grand Prairie Indep.

2009The supreme court has instructed us to liberally construe the rules in favor of preserving the right to appeal of a party who makes a bona fide1 attempt to invoke our jurisdiction, id. at 616 , and to give an appellant the opportunity to cure error when possible in favor of reaching the merits of an appeal, Warwick Towers Council of Co-Owners v. Park Warwick, L.P., 244 S.W.3d 838, 839 (Tex. 2008) (quoting Grand Prairie Indep.

22009–2009
Latisha Guillory v. Christopher Boykins green
texapp · 2014
1 sentence

2023Gabel, 649 S.W.3d at 596; Guillory, 3 442 S.W.3d at 689 .

12023–2023
Malooly Brothers, Inc. v. Napier green
tex · 1970
1 sentence

2018To be sure, some of these opinions relied on Malooly Bros., Inc. v. Napier , 461 S.W.2d 119 (Tex. 1970), for the proposition that a summary judgment will be upheld if the appellant fails to challenge a ground upon which the motion *323 may have been granted, notwithstanding that Malooly was grounded in the abandoned "point of error" designation regime and pre-dates the amendments to our rules, thus depriving the appellant of the opportunity to address the issue after having been given notice and the opportunity to cure under rule 38.9. 10 Of course rule 38.9(b) makes no distinction between bri

12018–2018
Martinez v. State green
texcrimapp · 2000
1 sentence

2015Martinez, 22 S.W.3d at 507 .

12015–2015

Statutes the citing opinions construe

TX § Tex. Penal Code § 21.11 (5) TX § Tex. Penal Code § 22.021 (5) TX § Tex. Penal Code § 12.42 (3) TX § Tex. Penal Code § 29.01 (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 45 (1988–2023) MI 16 (1994–2019) FL 7 (2000–2023) OK 7 (2000–2007) NY 6 (1980–2014) IL 4 (1992–2021) WA 3 (2022–2025) PA 2 (2020–2025) NM 2 (1989–2006) AZ 2 (1981–2015) VT 2 (2008–2013) IN 2 (2025–2025) CA 2 (2020–2026) KY 2 (2024–2025) OR 2 (2023–2025)

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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