01 · Headline finding

Of 0 Texas Business Court opinions in the corpus, 51 (54%) resolved on a threshold ground — jurisdictional, procedural, or early-procedurali — without adjudicating an underlying claim on the merits.

The corpus is, 19 months in, predominantly a jurisdictional-doctrine corpus. The split here separates opinions for which a discrete claim adjudication is coded (merits-reaching) from those resolving only on procedural or jurisdictional grounds without reaching the underlying claim (threshold). Eight of the threshold-side opinions carry merits-shaped early-procedural postures (4 Rule 166(g) early-legal-issue rulingsi; 4 Rule 91a dismissalsi); they are coded threshold because the disposition did not adjudicate a claim on its merits. Bucketing convention: threshold = jurisdiction-only postures (remand, special appearance, plea to jurisdiction, removability, transfer) plus Rule 91a, Rule 166(g), and motions to dismiss; merits = every other posture (n=44). Hover any segment for the per-posture breakdown; click to filter the matrix below. The early corpus is a jurisdictional map, not a mature merits corpus.

Threshold rulings — 51 opinions

    Merits-reaching — 44 opinions

      Hover a segment for the breakdown · click to filter the matrix

      Source note

      The Texas Judicial Branch provides short staff descriptions for public convenience. Those descriptions are not part of the opinions, are not official statements of the court, and are not legal authority. Texas Judicial Branch, Business Court Opinions. The Codex uses staff descriptions only for intake; all final coding traces to PDF paragraph pin cites in the opinions themselves. The threshold/merits split reflects a coded ruling_bucket (threshold / merits / mixed) validated against the PDF, not a mechanical inference from an empty claims field.

      Corpus snapshot & data coverage

      Corpus snapshot: 2024 Tex. Bus. 1 through 2026 Tex. Bus. 32, last checked May 23, 2026.

      Official PDF URL: 100%
      Date ISO: 100%
      Page count: 95%
      Fees / damages / AIC: coverage-limited
      Petition-level pleaded claims: pending docket backfill
      Claim taxonomy: discussed / adjudicated in opinion

      No corpus-level inference is drawn from fields with low coverage. Petition-level pleaded-claim coverage requires docket / pleading backfill and is not complete unless an opinion row is marked “pleading verified.” Where a claim count appears, it distinguishes claims discussed or adjudicated in the opinion from pleaded causes of action in the underlying petition; a single opinion may carry multiple values on the former axis.

      02 · From courtroom to outcome

      Division → procedural posture → ruling

      Every published opinion traces a single path. It enters at one of the five operational divisions (1st · Dallas, 3d · Austin, 4th · San Antonio, 8th · Fort Worth, 11th · Houston), encounters a specific procedural posture (motion to remandi, plea to the jurisdictioni, Rule 91ai, summary judgmenti), and exits with a ruling. Stream width tracks opinion volume; stream color encodes the ruling category.

      What to look for

      The corpus's largest single posture-disposition concentration: 13 of 18 remand-posturedi opinions (72%) resulted in the canonical disposition granted. Grants outnumber denials at remand by a wider margin than at any other posture in the corpus. Click any stream to filter the matrix below.

      Streams thinner than two opinions are dimmed for legibility. Rare postures and rulings are grouped under "Other".

      02.5 · Reader's reference

      Glossary — every term, in Plain English and Academic detail

      Every division, procedural posture, ruling type, and doctrinal anchor that appears in the Sankey above is defined here. Each card opens to a two-tab popup: a Plain-English tab with examples and analogies, and an Academic-detail tab with the black-letter rule, the controlling Texas Business Court opinion, and Bluebook 21st citations to primary sources. Two-tab pattern: SMU CGI, ExxonMobil Stress Tests, exxon-publication.netlify.app/stress_tests.

      Divisions

      The geographic units of the Texas Business Court. The 88th Texas Legislature created eleven divisions in HB 19; five — the 1st, 3d, 4th, 8th, and 11th — received funding and opened for filings on September 1, 2024. Tex. Gov't Code Ann. §§ 25A.002, 25A.003 (West 2024); HB 19, 88th Leg., R.S. (Tex. 2023). Across these five divisions the corpus contains 95 opinions (45 full published; 50 memorandum), October 2024 through May 2026.

      Procedural postures

      The specific motion or vehicle that put each opinion in front of the Court. These are the doctrinal levers — they determine the burden, the standard of review, and what the Court is actually deciding.

      Rulings

      "Granted" and "denied" carry posture-dependent operative consequences. A granted plea to the jurisdiction dismisses the suit for lack of subject-matter jurisdiction as filed; a granted motion to remand sends the action to the state district court from which it was removed. Posture and ruling must be read together. Of 13 granted remand motions in the corpus, 2 rest on § 25A.004(d) monetary-floor reasoning (Clean-Co under (d)(1); OWL Assetco I under (d)(2)); the remainder rest on commencement-date bars, counterparty status, or other statutory predicates.

      02.6 · Doctrines at a glance

      Five doctrines, by share of substantive holdings in the first 19 months

      Five doctrinal questions account for the largest share of substantive holdings in the corpus. Each is anchored in a specific statutory text, a controlling Texas Business Court opinion, and a practitioner-facing takeaway. Click any doctrine for plain-English meaning, the black-letter rule, the controlling TBC opinion, and the Bluebook authority.

      03 · What was being argued, in what shape

      Claims discussed or adjudicated × motion type

      Across the merits-reaching opinions, this matrix shows which claims travel with which motion types. Rows are the claims discussed or adjudicated in each opinion (coded from court text, not from petitions); columns are the motions that produced the opinion. Darker cells = more opinions at that intersection. Heatmap counts opinion-claim pairs (an opinion deciding multiple claims contributes once per claim); the merits-reaching tile counts opinions. Pair total ≠ opinion total when an opinion adjudicates more than one claim.

      What to look for

      On the heatmap's coding — claims on which an opinion's disposition actually operates on the merits — no single claim-by-posture cell dominates the early corpus. The largest cell is breach of fiduciary duty × other-merits rulings at 4 opinions, followed by breach of contract × summary judgment at 3. A broader pleaded-claim coding (claims present in the complaint but not necessarily reached on the merits) produces a larger contract footprint and is reported separately in the Methods section. Click any cell to drill into those opinions.

      1 ·

      04 · Doctrine deep dive

      Clean-Co Systems v. Enterprise Products Operating — the springing-aggregation question under § 25A.004(d)(1)

      In Clean-Co Systems v. Enterprise Products Operating, 2026 Tex. Bus. 32 (Dorfman, J., 11th Div., May 20, 2026), Enterprise argued that a "qualified transaction"i within the meaning of Tex. Gov't Code Ann. § 25A.001(14) (jurisdictional grant at § 25A.004(d)(1)) is established once cumulative payments under a long-running master service agreement clear the $5 million aggregate-value threshold, even when the single purchase order in dispute is itself for less than $1 million. The slider below illustrates how that aggregation would reshape the jurisdictional analysis.

      The doctrinal point

      Judge Dorfman granted remand on one dispositive ground: the historical purchase orders invoked by Enterprise do not constitute a qualifying "series of related transactions" under Tex. Gov't Code § 25A.004(d)(1) because they "spanned more than two decades, involved differing scopes of work, and were performed at diverse facilities." The Court separately sustained a hearsay objection to Enterprise's Oracle payment records. Judge Dorfman expressly rested the remand on the related-transactions ground; the opinion does not state, and does not depend on, the evidentiary ruling as an alternative ground. The holding is fact-bound rather than categorical. The Court did not announce a per-se rule against aggregation under § 25A.001(14); it held that the MSA history before it did not constitute "a series of related transactions" on the facts pleaded. Clean-Co is, as of the date of this audit, the first Texas Business Court opinion to decline a springing-aggregation theory under the § 25A.004(d)(1) qualified-transaction floor; § 25A.004(d)(2)'s amount-in-controversy threshold is doctrinally separate and not at issue. Of 13 opinions in which the procedural posture is remand and the canonical disposition is granted, only two turn on a § 25A.004(d) monetary floor: Clean-Co (§ 25A.004(d)(1) qualified-transaction floor) and 2025 Tex. Bus. 30, OWL Assetco I v. EOG Resources (Bullard, J.) (§ 25A.004(d)(2) amount-in-controversy floor, addressing aggregation of joined-party claims under § 25A.004(i)). The remaining 11 turn on commencement-date bars (HB 19 § 8i), counterparty status (TBC jurisdiction over non-business-court parties), or other statutory predicates.

      This case · single purchase order

      < $1M

      Amount in controversy on the disputed PO. Standing alone, well below § 25A.004(d)(1)'s qualified-transaction threshold — $5 million post-HB 40 (effective Sept. 1, 2025); $10 million under HB 19 for filings predating Sept. 1, 2025. Clean-Co was decided May 20, 2026 under the post-HB 40 regime. The separate § 25A.004(d)(2) amount-in-controversy basis ($10 million for non-qualified contract and statutory-violation actions) is not at issue here.

      Cumulative payments under the 2003 MSA (slider)

      $0.0M

      $0 $2.5M $5M $7.8M

      Not a qualified transaction — single PO under $1M, no springing aggregation.

      Court's reasoning

      "The historical purchase orders on which the defendant relies spanned more than two decades, involved differing scopes of work, and were performed at diverse facilities — potentially operated by different affiliated entities. Only one such purchase order is at issue in this case. The remainder are not in controversy."

      — Dorfman, J., 2026 Tex. Bus. 32

      Takeaway. On the facts of Clean-Co, cumulative payment history under a multi-decade MSA — totaling approximately $7.8 million across the historical purchase orders — did not satisfy the "series of related transactions" requirement of § 25A.001(14) for the under-$1 million purchase order in dispute. The plaintiff's motion to remand was granted. The Court did not foreclose a § 25A.001(14) aggregation theory on different facts.

      Adjacent doctrine in the corpus: · · .

      05 · Who is writing the doctrine

      The bench at a glance

      Ten Business Court judges have authored published opinions in the corpus's first 19 months. Each card shows that judge's opinion volume, grant rate, share of threshold-only rulings, and doctrinal signature — the procedural posture each judge has authored most often. Counts describe opinion output, not case difficulty, caseload, reversal risk, or judicial quality.

      What to look for

      Whitehill (18) and Bullard (17) are the corpus's highest-output opinion authors; together they account for 35 of 95 opinions (37%). Bullard authored the leading opinions on HB 40 retroactivityi (2025 Tex. Bus. 47); Bullard also authored the AIC-aggregation remand in 2025 Tex. Bus. 30 (OWL Assetco I v. EOG Resources) under § 25A.004(d)(2), a separate qualified-transaction question from HB 40 retroactivity. Adrogué authored the leading opinions on the HB 19 § 8 commencement-date bar (2024 Tex. Bus. 8; 2025 Tex. Bus. 2 and 8); Andrews authored the leading opinions on Rule 166(g)i early-legal-issue rulings and on the Marathon Oil force-majeurei arc; Dorfman authored Clean-Co Systems. Click a card to read those opinions.

      Sort by:

      06 · Repeat appearances in published opinions

      Repeat-appearance ribbon

      Fifteen captions account for 38 of 95 opinions (40%). Each horizontal lane is one caption; each dot is one opinion, positioned on a time axis from October 2024 to today and color-coded by ruling. "Caption" denotes a distinct adverse-party pairing as it appears on the face of the opinion; captions are not deduplicated by underlying business dispute.

      The litigation arc

      Primexx Energy Opportunity Fund v. Primexx Energy Corporation generated five opinions across partnership, drag-along, fiduciary-duty, and personal-jurisdiction questions. Slant Operating v. Octane Energy Operating produced four. Marathon Oil v. Mercuria Energy America traces the Winter Storm Uri force-majeure arc across three opinions (two published, one memorandum). A small set of multi-opinion captions accounts for a substantial share of the corpus's published output to date.

      Time axis: October 2024 (court's first published opinion) → today. Lanes ordered by total opinion count descending.

      07 · Every opinion

      Filter, sort, drill into the full corpus

      All 95 Texas Business Court opinions (45 published, 50 memorandum), citation by citation. Use the filter chips, the search box, or click any visualization above to drill in. Sort by clicking a column header. Export the filtered set as CSV.

      Showing 95 of 95 opinions
      Citation Date Case Div. Judge Posture Ruling Claims / Issues  

      08 · How to cite this work

      How to cite this work

      This is a living research product: the underlying corpus and analysis are versioned and updated as the court issues new opinions. The dataset and the interpretive analysis are co-citable.

      Bluebook

      Shane Goodwin, The Texas Business Court Codex v1.2.3, SMU Corp. Governance Initiative (May 23, 2026), https://smucgi.pages.dev/research/texas-business-court/dashboard/ (last visited [date of access]).

      Companion paper: Shane Goodwin, The Texas Business Court Codex: A Doctrinal Audit of the First Nineteen Months (SMU Corp. Gov. Init. Working Paper No. 2026c, forthcoming SSRN).

      APA

      Goodwin, S. (2026). The Texas Business Court Codex (Version v1.2.3) [Interactive dataset and doctrinal analysis]. SMU Corporate Governance Initiative. https://smucgi.pages.dev/research/texas-business-court/dashboard/

      BibTeX

      @misc{goodwin2026tbccodex,
  author    = {Shane Goodwin},
  title     = {The Texas Business Court Codex},
  year      = {2026},
  version   = {v1.2.3},
  publisher = {SMU Corporate Governance Initiative},
  howpublished = {\url{https://smucgi.pages.dev/research/texas-business-court/dashboard/}},
  note      = {Underlying corpus: 95 Texas Business Court opinions (45 published, 50 memorandum), October 2024 -- present. Accessed [date].}
}

      Dataset (Bluebook)

      Shane Goodwin, The TBC Opinions Master Matrix (v1.2.3), SMU Corp. Governance Initiative (May 23, 2026), https://smucgi.pages.dev/research/texas-business-court/dashboard/tbc_opinions.json.

      Contributor roles (CRediT taxonomy)

      Shane Goodwin — Conceptualization · Methodology · Investigation · Data curation · Formal analysis · Software · Visualization · Writing — original draft · Writing — review & editing · Project administration · Supervision. Editorial review — SMU CGI research staff. Citation verification & visualization implementation — research assistance via the Claude agent.