The Texas Civ Pro Pass
The Texas civil-procedure traps that decide cases before the merits do — each with its rule and the surface that handles it. This is the checklist an attorney runs; running it is your choice.
The Monday rule
TRCP 99(b)The answer is due by 10 a.m. on the Monday after 20 days — not simply '20 days.' Miss it and a default follows.
Handle it →The due-order of pleadings
TRCP 120aA special appearance must be FIRST — file anything else ahead of it and the jurisdiction challenge is waived.
Handle it →The wrong motion vehicle
TRCP 90/91/91aTexas has no FL-style motion to dismiss — it has special exceptions (repleader) and Rule 91a (baseless-claim, fee-shifting).
Handle it →The discovery Level
TRCP 190The plaintiff must plead the level, and the level sets your deposition hours and interrogatory count — pick your discovery inside the budget.
Handle it →The 50-day early-service trap
TRCP 196-198Discovery served before the answer is due gets 50 days to respond, not 30 — an easy miscalculation.
Handle it →Deemed admissions
TRCP 198.2(c)An unanswered request for admission is admitted without a court order, and admitted matters are conclusively established.
Handle it →The amended MSJ clock
TRCP 166a (2026 ed.)The summary-judgment timing was rewritten effective July 1, 2026 — filing-relative now, not hearing-relative.
Handle it →Charge preservation
TRCP 272-274Objections to the charge come before it is read and must point out the error DISTINCTLY — a general objection preserves nothing.
Handle it →The plenary-power horizon
TRCP 329bThe trial court's power over the judgment expires on a computable date (30 -> up to 75 -> +30) — the malpractice clock.
Handle it →