Case Citations

999 case law citations with propositions — what each case was cited for

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291 rows where cited_by = "Pohl"

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  • Pohl · 291 ✖
citation_id ▼ filing_id case_name citation court year proposition cited_by
30 9 9 In re Lipsky 460 S.W.3d 579 Texas Supreme Court 2015 TCPA is intended to dismiss lawsuits designed to chill First Amendment rights, not to dismiss meritorious lawsuits; prima facie case requires 'minimum quantum of evidence' supporting rational inference allegation is true; pleading showing factual basis for claim is sufficient to resist TCPA motion Pohl
31 9 9 Wayne Dolcefino & Dolcefino Communications, LLC v. Cypress Creek EMS 540 S.W.3d 194 Tex. App.—Houston [1st Dist.] 2017 Courts use a two-step procedure for TCPA dismissal; must view evidence in light most favorable to nonmovant; must show connection between claims and alleged protected conduct Pohl
32 9 9 ExxonMobil Pipeline Co. v. Coleman 512 S.W.3d 895 Texas Supreme Court 2017 Legislature included expedited manner for dismissing claims brought to intimidate or silence defendants' First Amendment rights Pohl
33 9 9 LFMC Enterprises, LLC v. Baker 546 S.W.3d 893 Tex. App.—Houston [1st Dist.] 2018 Movant bears burden of demonstrating TCPA applicability by preponderance of evidence; rights being protected must be the party's own rights, not a third party's; defendant must demonstrate specific connection between claim and protected right Pohl
34 9 9 Hersh v. Tatum 526 S.W.3d 462 Texas Supreme Court 2017 Basis of a legal action is determined by the plaintiff's allegations, not the defendant's admissions or denials; petition is the 'best and all-sufficient evidence of the nature of the action' Pohl
35 9 9 Sloat v. Rathbun 513 S.W.3d 500 Tex. App.—Austin 2015 Courts should not blindly accept defendants' attempts to characterize claims as implicating protected expression; should favor conclusion that claims are not predicated on protected expression; defendant's activities not factually predicate for claims are not pertinent to the inquiry Pohl
36 9 9 Castleman v. Internet Money Ltd. 546 S.W.3d 684 Texas Supreme Court 2018 Four-part test for commercial speech exception: (1) defendant primarily engaged in selling/leasing goods or services, (2) conduct in defendant's capacity as seller, (3) arose out of commercial transaction involving defendant's services, (4) intended audience was actual or potential customers Pohl
37 9 9 Miller Weisbrod, L.L.P. v. Llamas-Soforo 511 S.W.3d 181 Tex. App.—El Paso 2014 Attorney advertising falls within the commercial exception to the TCPA Pohl
38 9 9 NCDR, L.L.C. v. Mauze v. Bagby, P.L.L.C. 745 F.3d 742 U.S. Court of Appeals, Fifth Circuit 2014 Where a lawyer is primarily engaged in selling legal services and the speech arises from the sale of services to actual/potential clients, the solicitation falls outside TCPA protections Pohl
39 9 9 Hicks v. Group & Pension Administrators, Inc. 473 S.W.3d 518 Tex. App.—Corpus Christi 2015 Detailed pleading showing factual basis for claims is sufficient to set forth prima facie case under the TCPA Pohl
40 9 9 In re E.I DuPont de Nemours & Co. 136 S.W.3d 218 Texas Supreme Court 2004 Prima facie case requires 'minimum quantum of evidence necessary to support a rational inference that the allegation of fact is true' Pohl
41 9 9 Stockyards Nat. Bank v. Maples 95 S.W.2d 1300 Tex. Comm'n App. 1936 The petition is the 'best and all-sufficient evidence of the nature of the action' Pohl
42 9 9 Cantey Hanger, LLP v. Byrd 467 S.W.3d 477 Texas Supreme Court 2015 Attorney immunity protects actions taken while representing a client in litigation; Pohl argues Kassab had no clients at time of wrongful conduct Pohl
43 9 9 Mayes v. Stewart 316 S.W.3d 715 Tex. App.—Houston [14th Dist.] 2010 Two-year limitations for conspiracy; Pohl argues limitations has not run because Favre-Kassab Agreement was November 10, 2016 Pohl
44 9 9 Collins v. Collins 2018 WL 1320841 Tex. App.—Houston [1st Dist.] 2018 Distinguished — that case involved claims factually predicated on communications in a judicial proceeding (divorce affidavit), unlike Pohl's claims for conversion of stolen property Pohl
45 9 9 Reeves v. Harbor Am. Cent., Inc. 552 S.W.3d 389 Tex. App.—Houston [14th Dist.] 2018 Distinguished — that case simply held the trial court must conduct a full TCPA analysis rather than summarily concluding TCPA does not apply; Pohl does not deny TCPA analysis is required Pohl
69 15 15 In re Roser 2016 WL 2605686 Tex. App.—Houston [14th Dist.] 2016 Mandatory stay under § 51.014(b) applies to all trial court proceedings including discovery Pohl
70 15 15 In re Texas Educ. Agency 441 S.W.3d 747 Tex. App.—Austin 2014 Conducting hearings during mandatory stay was abuse of discretion violating § 51.014(b) Pohl
71 15 15 In re Bliss & Glennon, Inc. 2014 WL 50831 Tex. App.—Houston [1st Dist.] 2014 Mandamus relief granted when trial court took action during mandatory stay under § 51.014(b) Pohl
72 15 15 Roccaforte v. Jefferson County 341 S.W.3d 919 Texas Supreme Court 2011 Trial court actions taken in violation of § 51.014(b) stay are voidable, not void Pohl
73 15 15 Bacharach v. Garcia 485 S.W.3d 600 Tex. App.—Houston [14th Dist.] 2016 TCPA 60-day filing period begins from service of original petition and is not reset by amended petitions Pohl
74 15 15 Wheeler v. Green 157 S.W.3d 439 Texas Supreme Court 2005 Lawyer's failure to meet a deadline is an elementary mistake that could warrant conclusion of intent or conscious indifference Pohl
75 15 15 LFMC Enterprises, LLC v. Baker 546 S.W.3d 893 Tex. App.—Houston [1st Dist.] 2018 Defendants bear burden of demonstrating TCPA applicability by preponderance of evidence Pohl
76 15 15 In re Lipsky 460 S.W.3d 579 Texas Supreme Court 2015 TCPA is intended to dismiss lawsuits designed to chill First Amendment rights, not dismiss meritorious lawsuits; defines prima facie case standard; 'clear' means unambiguous, sure, free from doubt; 'specific' means explicit or relating to a particular named thing Pohl
77 15 15 Wayne Dolcefino & Dolcefino Communications, LLC v. Cypress Creek EMS 540 S.W.3d 194 Tex. App.—Houston [1st Dist.] 2017 Two-step TCPA procedure; movant must establish connection between claims and protected conduct; evidence viewed in light most favorable to nonmovant Pohl
78 15 15 ExxonMobil Pipeline Co. v. Coleman 512 S.W.3d 895 Texas Supreme Court 2017 Two-step TCPA procedure for expediting dismissal of claims chilling First Amendment rights Pohl
79 15 15 Hersh v. Tatum 526 S.W.3d 462 Texas Supreme Court 2017 Basis of legal action determined by plaintiff's allegations, not defendant's characterizations; petition is the best and all-sufficient evidence of the nature of the action Pohl
80 15 15 Sloat v. Rathbun 513 S.W.3d 500 Tex. App.—Austin 2015 Courts should not blindly accept defendant's recharacterization of claims; should favor conclusion claims are not predicated on protected expression; activities not factual predicate for claims are not pertinent Pohl
81 15 15 Castleman v. Internet Money Ltd. 546 S.W.3d 684 Texas Supreme Court 2018 Four-part test for TCPA commercial speech exception under § 27.010(b); discusses how the 'capacity' of the person is relevant to whether they were primarily engaged in selling goods or services Pohl
82 15 15 In re E.I. DuPont de Nemours & Co. 136 S.W.3d 218 Texas Supreme Court 2004 Prima facie case is minimum quantum of evidence to support rational inference that allegation of fact is true Pohl
83 15 15 S & S Emergency Training Sols., Inc. v. Elliott 2018 WL 6711322 Texas Supreme Court 2018 Defining 'clear and specific' evidence requirement under TCPA Pohl
84 15 15 Hicks v. Group & Pension Administrators, Inc. 473 S.W.3d 518 Tex. App.—Corpus Christi 2015 Detailed pleading allegations sufficient to establish prima facie case under TCPA Pohl
85 15 15 Prime Products, Inc. v. S.S.I. Plastics, Inc. 97 S.W.3d 631 Tex. App.—Houston [1st Dist.] 2002 Elements of a breach of contract claim Pohl
86 15 15 Stockyards Nat. Bank v. Maples 95 S.W.2d 1300 Tex. Comm'n App. 1936 Petition is the best and all-sufficient evidence of the nature of the action Pohl
87 15 15 Sullivan v. Abraham 488 S.W.3d 294 Texas Supreme Court 2016 Movant bears burden of proof on attorney's fees including documentation of services, hourly rates, and time required Pohl
88 15 15 Stine v. Stewart 80 S.W.3d 586 Texas Supreme Court 2002 Four-year statute of limitations for breach of contract Pohl
89 15 15 Mayes v. Stewart 316 S.W.3d 715 Tex. App.—Houston [1st Dist.] 2006 Limitations periods for civil conspiracy claims follow the underlying torts Pohl
124 17 17 Regency Field Services, LLC v. Swift Energy Operating, LLC 622 S.W.3d 807 Tex. 2021 Defendant seeking summary judgment on limitations must conclusively establish that limitations expired before suit was filed; must negate discovery rule; claim accrues when defendant's wrongful conduct causes legal injury Pohl
125 17 17 Burns v. Rochon 190 S.W.3d 263 Tex. App.—Houston [1st Dist.] 2006 Conversion claim accrues at time of defendant's unlawful taking Pohl
126 17 17 Pemex Exploracion y Produccion v. BASF Corp. 2013 WL 5514944 S.D. Tex. 2013 Each possession of converted property is a new conversion (applying Texas law) Pohl
127 17 17 Sw. Energy Prod. Co. v. Berry-Helfand 491 S.W.3d 699 Tex. 2016 Trade secret misappropriation accrues when the trade secret is actually used commercially; use means commercial use by which the offending party seeks to profit Pohl
128 17 17 Agar Corp., Inc. v. Electro Circuits Int'l, LLC 580 S.W.3d 136 Tex. 2019 Civil conspiracy accrues as to each underlying tort when that tort occurs Pohl
129 17 17 Burchfield v. Prosperity Bank 408 S.W.3d 542 Tex. App.—Houston [1st Dist.] 2013 Res judicata requires prior final judgment, identity of parties or those in privity, and second action based on same claims that were or could have been raised; three-part test for privity: control, representation of interests, successor in interest Pohl
130 17 17 Amstadt v. U.S. Brass Corp. 919 S.W.2d 644 Tex. 1996 Three tests for privity: control over action, interests represented by a party, successor in interest Pohl
131 17 17 Rogers v. Walker 2013 WL 2298449 Tex. App.—Corpus Christi 2013 Allegations of conspiracy alone insufficient to establish privity; movant must show one of three privity tests is satisfied; refusing to affirm summary judgment when movant did not state interest or evidence of representation Pohl
132 17 17 New York Pizzeria, Inc. v. Syal 53 F. Supp. 3d 962 S.D. Tex. 2014 Texas Supreme Court would not adopt blanket rule that coconspirators are always in privity for claim preclusion; courts must consider circumstances Pohl
133 17 17 McNeil Interests, Inc. v. Quisenberry 407 S.W.3d 381 Tex. App.—Houston [14th Dist.] 2013 Privity through control requires active and open participation in prior proceedings to such extent it was clear the individual had right to direct them Pohl
134 17 17 Citizens Ins. Co. of Am. v. Daccach 217 S.W.3d 430 Tex. 2007 For res judicata, court looks to factual matters making up the gist of the complaint without regard to form of action; considers relatedness in time, space, origin, motivation; considers whether facts form a convenient trial unit Pohl
135 17 17 Barr v. Resolution Tr. Corp. ex rel. Sunbelt Fed. Sav. 837 S.W.2d 627 Tex. 1992 Subsequent suit barred if it arises out of same subject matter AND could have been litigated in prior suit through exercise of diligence Pohl
136 17 17 Youngkin v. Hines 546 S.W.3d 675 Tex. 2018 Two inquiries for attorney immunity: type of conduct and existence of attorney-client relationship at the time; conduct must be within scope of representation and not foreign to duties of a lawyer Pohl
137 17 17 Cantey Hanger, LLP v. Byrd 467 S.W.3d 477 Tex. 2015 Attorney immunity requires conduct within scope of client representation that is not foreign to duties of attorney; the kind of conduct in which an attorney engages when discharging duties to client Pohl
138 17 17 Landry's, Inc. v. Animal Legal Def. Fund 2021 WL 2021130 Tex. 2021 Attorney immunity requires conduct in 'uniquely lawyerly capacity' particular to the office, professional training, skill, and authority of an attorney Pohl
139 17 17 Tanox, Inc. v. Akin, Gump, Strauss, Hauer & Feld, L.L.P. 105 S.W.3d 244 Tex. App.—Houston [14th Dist.] 2003 Attorney-client relationship cannot be formed prior to 'meeting of the minds' between potential client and attorney Pohl
140 17 17 Kassab v. Pohl 612 S.W.3d 571 Tex. App.—Houston [1st Dist.] 2020 First Court of Appeals characterized Kassab's conduct as arising from commercial transaction involving legal services; Pohl argues this does not establish attorney immunity, as it addresses scope of transaction not scope of duties to client Pohl
141 17 17 RSM Prod. Corp. v. Freshfields Bruckhaus Deringer U.S. LLP 800 F. Supp. 2d 182 D.D.C. 2011 Distinguished by Pohl: in RSM, plaintiff attempted to assert the exact same conspiracy in a new action; here the conspiracy was not part of the Federal Court Case Pohl
174 21 21 Horizon/CMS Healthcare Corp. v. Auld 34 S.W.3d 887 Tex. 2000 An opposing party should use special exceptions to identify defects in a pleading so they may be cured, if possible, by amendment Pohl
175 21 21 Baylor Univ. v. Sonnichsen 221 S.W.3d 632 Tex. 2007 The purpose of a special exception is to compel clarification of pleadings when they are not clear or sufficiently specific or fail to plead a cause of action Pohl
176 21 21 Sw. Bell Tel. Co. v. Garza 164 S.W.3d 607 Tex. 2004 Special exceptions are the appropriate vehicle to force clarification of claims when a party is in doubt Pohl
177 21 21 In re Mem'l Hermann Hosp. Sys. 464 S.W.3d 686 Tex. 2015 Special exceptions are the appropriate vehicle by which an adverse party may force clarification of vague pleadings, thereby narrowing the range of facts of consequence in the action Pohl
178 22 22 Houtex Ready Mix Concrete & Materials v. Eagle Const. & Envtl. Services, L.P. 226 S.W.3d 514 Tex. App.—Houston [1st Dist.] 2006 Res judicata prevents parties and those in privity from relitigating a case adjudicated to finality; requires prior final judgment on merits, identity of parties or privity, and second action on same claims Pohl
179 22 22 Gonzalez v. Guilbot 315 S.W.3d 533 Tex. 2010 A judgment is final for purposes of res judicata even if it is appealed Pohl
180 22 22 Igal v. Brightstar Info. Tech. Group, Inc. 250 S.W.3d 78 Tex. 2008 A decision based on the statute of limitations is a decision on the merits for res judicata purposes Pohl
181 22 22 Livingston v. U.S. Bank Nat'l Ass'n 2020 WL 1646741 Tex. App.—Fort Worth 2020 Resolution on statute of limitations has no bearing on the preclusive effect of res judicata Pohl
182 22 22 Samuel v. Fed. Home Loan Mortg. Corp. 434 S.W.3d 230 Tex. App.—Houston [1st Dist.] 2014 A party is in privity with a party to a prior action when the party is a successor-in-interest deriving its claim through a party to the prior action Pohl
183 22 22 Amstadt v. U.S. Brass Corp. 919 S.W.2d 644 Tex. 1996 Successors in interest are in privity with plaintiffs to prior lawsuit Pohl
184 22 22 Gandy v. Williamson 2021 WL 2149833 Tex. App.—Houston [1st Dist.] 2021 A claim for barratry accrues when a potential client is improperly solicited; the date of client's contract signature demonstrates when solicitation occurred; barratry claims are subject to up to four-year limitations; two-year limitations applies if no contract resulted Pohl
185 22 22 Brumfield v. Williamson 2021 WL 2149335 Tex. App.—Houston [1st Dist.] 2021 Affirmed summary judgment dismissing barratry claims on limitations Pohl
186 22 22 Pitts & Collard, L.L.P. v. Schechter 369 S.W.3d 301 Tex. App.—Houston [1st Dist.] 2011 Section 16.069 is a savings clause intended to prevent a plaintiff from waiting until an adversary's valid claim was barred by limitations before asserting his own claim; applies logical relationship test Pohl
187 22 22 Smith v. Ferguson 160 S.W.3d 115 Tex. App.—Dallas 2005 The essential facts on which the counterclaim is based must be significantly and logically relevant to both claims under the logical relationship test Pohl
188 22 22 Freeman v. Cherokee Water Co. 11 S.W.3d 480 Tex. App.—Texarkana 2000 Claim requesting interpretation of a deed provision and counterclaim attacking validity of entire deed did not satisfy the logical relationship test Pohl
189 22 22 Wright v. Matthews 26 S.W.3d 575 Tex. App.—Beaumont 2000 Counterclaim for breach of sales contract and action to quiet title did not arise out of same transaction or occurrence Pohl
190 22 22 T&C Constr., Ltd. v. Brown Mech. Services, Inc. 2020 WL 3866659 Tex. App.—Houston [1st Dist.] 2020 Section 16.069 did not apply where contractor's unjust enrichment counterclaim regarding Project 1 overpayment was not logically related to subcontractor's breach of contract claim regarding Project 2 Pohl
191 22 22 Rogers v. Ardella Veigel Inter Vivos Tr. No. 2 162 S.W.3d 281 Tex. App.—Amarillo 2005 A counterclaim must provide fair notice under Rule 47 to satisfy section 16.069's timing requirement; allegations must be sufficient to inform a reasonably competent attorney of the nature and basic issues of the controversy Pohl
192 22 22 Holman St. Baptist Church v. Jefferson 317 S.W.3d 540 Tex. App.—Houston [14th Dist.] 2010 Section 16.069(a) is intended to prevent a party from waiting until an opponent's valid claim is time-barred before asserting its own claim; courts have limited its reach Pohl
193 22 22 J.M.K. 6, Inc. v. Gregg & Gregg, P.C. 192 S.W.3d 189 Tex. App.—Houston [14th Dist.] 2006 Section 16.069 allows parties already in the action to assert otherwise time-barred claims against one another Pohl
194 22 22 Ball v. SBC Communications, Inc. 2003 WL 21467219 Tex. App.—San Antonio 2003 Courts apply the Code Construction Act when construing § 16.069; the court limited § 16.069's reach based on object, purpose, consequences, and public interest; public interest would be hindered by allowing circumvention of limitations Pohl
195 22 22 Swoboda v. Ocwen Loan Servicing, LLC 579 S.W.3d 628 Tex. App.—Houston [14th Dist.] 2019 Cited Ball's construction of § 16.069 with approval Pohl
196 22 22 Tex. Farm Bureau Mut. Ins. Co. v. Rogers 351 S.W.3d 103 Tex. App.—San Antonio 2011 A statutory cause of action that does not explicitly provide for survival and is punitive in nature does not survive a plaintiff's death and is not assignable Pohl
197 22 22 PPG Industries, Inc. v. JMB/Houston Centers Partners Ltd. P'ship 146 S.W.3d 79 Tex. 2004 Four-factor test for assignability of statutory claims: (1) statutory text, (2) statutory purpose, (3) related common-law principles, (4) whether assignment increases litigation; personal and punitive aspects of DTPA claims cannot be squared with free assignability; assignability of most claims does not mean all are assignable; exceptions may be required due to equity and public policy Pohl
198 22 22 State v. Oakley 227 S.W.3d 58 Tex. 2007 A claim must be capable of surviving the plaintiff's death to be assignable Pohl
199 22 22 In re Xerox Corp. 555 S.W.3d 518 Tex. 2018 Penalties are by their nature punitive Pohl
200 22 22 Sw. Bell Tel. Co. v. Mktg. on Hold Inc. 308 S.W.3d 909 Tex. 2010 Assignments may be invalidated on public policy grounds; assignments that tend to increase or prolong litigation unnecessarily or are transparent devices to increase and distort litigation may be void Pohl
201 22 22 Am. Homeowner Pres. Fund, LP v. Pirkle 475 S.W.3d 507 Tex. App.—Fort Worth 2015 Courts should inquire whether notions of equity and public policy would vitiate the assignment of a claim under the circumstances; found assignment encouraged litigation rather than curbing it Pohl
202 22 22 LAKXN Income, Inc. v. TLC Hosp., LLC 2021 WL 3085755 Tex. App.—Fort Worth 2021 Assignments used as transparent devices to increase and distort litigation are subject to invalidation Pohl
203 22 22 State Farm Fire & Cas. Co. v. Gandy 925 S.W.2d 696 Tex. 1996 Courts have invalidated assignments that distort the litigation process Pohl
204 22 22 Wright v. Sydow 173 S.W.3d 534 Tex. App.—Houston [14th Dist.] 2004 Assignments made solely to circumvent settlement agreement releases violated strong public policy favoring voluntary settlements and were void; a court may consider whether assignment has tendency to injure the public good Pohl
205 22 22 Newco Drilling Co. v. Weyand 960 S.W.2d 654 Tex. 1998 Initial partial summary judgment rulings become final upon the court resolving the remaining issues in the case Pohl
237 24 24 Marino v. State Farm Fire & Cas. Ins. Co. 787 S.W.2d 948 Tex. 1990 Distinguished — Marino dealt with a cause of action not recognized until after the first judgment (bad faith tort claim); here, the barratry claims existed and were adjudicated before the purported assignments Pohl
238 24 24 City of Lubbock v. Stubbs 327 S.W.2d 411 Tex. 1959 Distinguished — Stubbs involved a new zoning ordinance and different 'present use' of land in each suit; here Kassab asserts the exact same claims that were previously adjudicated Pohl
239 24 24 Hernandez v. Del Ray Chem. Intern., Inc. 56 S.W.3d 112 Tex. App.—Houston [14th Dist.] 2001 Courts focus on whether a claim existed and was 'a claim that was raised or that could have been raised in the first action' Pohl
240 24 24 Commint Tech. Services, Inc. v. Quickel 314 S.W.3d 646 Tex. App.—Houston [14th Dist.] 2010 Kassab's own cited case states the logical relationship test 'is met when the same facts, which may or may not be disputed, are significant and logically relevant to both claims' — Kassab omitted 'significant' Pohl
241 24 24 Smith v. Ferguson 160 S.W.3d 115 Tex. App.—Dallas 2005 Section 16.069 does not apply when the essential facts on which the counterclaim is based are not significantly and logically relevant to both claims Pohl
242 24 24 Ball v. SBC Communications, Inc. 2003 WL 21467219 Tex. App.—San Antonio 2003 Public interest would be hindered by allowing a party to circumvent limitations by relying on section 16.069 Pohl
243 24 24 Ferguson v. Bldg. Materials Corp. of Am. 295 S.W.3d 642 Tex. 2009 Judicial estoppel precludes a party who 'successfully maintains' a position from adopting a clearly inconsistent position; Kassab omitted the 'successfully' requirement Pohl
244 24 24 PPG Industries, Inc. v. JMB/Houston Centers Partners Ltd. P'ship 146 S.W.3d 79 Tex. 2004 The four-factor assignability analysis applies beyond DTPA claims; 'the assignability of most claims does not mean all are assignable; exceptions may be required due to equity and public policy'; risks of distortion concern the class of claims; legislature's silence on assignability 'can be significant' Pohl
245 24 24 Sw. Bell Tel. Co. v. Mktg. on Hold Inc. 308 S.W.3d 909 Tex. 2010 Assignments that tend to increase or prolong litigation unnecessarily or serve as transparent devices to increase and distort litigation may be void Pohl
246 24 24 LAKXN Income, Inc. v. TLC Hosp., LLC 2021 WL 3085755 Tex. App.—Fort Worth 2021 Assignments used as transparent devices to increase and distort litigation are subject to invalidation Pohl
247 24 24 Kassab v. Pohl 612 S.W.3d 571 Tex. App.—Houston [1st Dist.] 2020 Kassab's citation to this case's discussion of 'past litigation' does not constitute competent evidence of unclean hands Pohl
248 24 24 M.A. Mills, P.C. v. Kotts 2022 WL 176125 Tex. App.—Houston [14th Dist.] 2022 Kassab misleadingly cited — court explicitly stated courts 'may deem these rules to be an expression of public policy, so that a contract violating them is unenforceable as against public policy' — the word 'may' gives courts discretion, not a prohibition Pohl
249 24 24 Low v. Henry 221 S.W.3d 609 Tex. 2007 Fair notice requires a party to be able to ascertain the nature, basic issues, and type of relevant evidence from the pleading Pohl

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CREATE TABLE citations (
    citation_id INTEGER PRIMARY KEY AUTOINCREMENT,
    filing_id INTEGER REFERENCES filings(filing_id),
    case_name TEXT,
    citation TEXT,
    court TEXT,
    year INTEGER,
    proposition TEXT,
    cited_by TEXT
);