John Henry & Associates
Texas corpus · live
Tex. R. Civ. P. 86 · you have been sued in the wrong county

The venue motion goes first, or it does not go at all.

Texas does not give you a number of days to object to venue. It gives you a position in the order of pleading. The motion to transfer must be filed before or at the same time as any other plea, pleading or motion — with one exception, a special appearance.

File an answer first and say nothing about venue, and the objection is generally gone. Not weakened. Gone.

or answer two questions
Due order of pleading · Rule 86(1)

What has been filed on your behalf so far?

This is the whole question. Venue is not lost by a calendar — it is lost by filing something else first.

Where it is, and where it should be

Two counties matter: the one you were sued in, and the one you say it belongs in. The gap between them is the motion. The county also decides which court of appeals binds your trial judge, and venue law is a place where the districts do not always read the same.

One question that changes everything

Some venue provisions are mandatory. If one applies, the analysis is not about convenience or where the witnesses are — the case has to go, and the trial court has no discretion to keep it.

Where these answers come from

We hold the published Texas case law in our own index and query it directly. No vendor sits between the question and the answer. That is the reason a discrete motion can carry a price on a web page instead of an hourly rate and a hope.

881,255
Texas decisions indexed
6 ms
Median query, this posture
841,641
Parallel citations mapped
26 Jun 2026
Index current through

Authority that may bear on your posture Attorney reviewed

Pulled from our index for this mechanism and read by a lawyer before it went on this page. A green check means the decision is on point for this posture. It is not a statement that the case has been shepardized, and it is not a representation about its current precedential standing.

Surgitek, Bristol-Myers Corp. v. Abel
997 S.W.2d 598 (Tex. 1999)
How venue is actually proved. Once venue facts are specifically denied, the party pleading them must make prima facie proof — and the trial court takes that proof as true. Most venue motions are won or lost on this mechanic, not on the merits.
cited by
295
Ruiz v. Conoco, Inc.
868 S.W.2d 752 (Tex. 1994)
What counts as prima facie proof of a venue fact, and what a court may and may not consider on the papers.
cited by
327
Curtis v. Gibbs
511 S.W.2d 263 (Tex. 1974)
The due-order rule and what waives it. The reason this page opens by asking what you filed rather than when you were served.
cited by
325
In re Missouri Pacific Railroad Co.
998 S.W.2d 212 (Tex. 1999)
Mandamus where a mandatory venue provision is ignored — the route when the trial court refuses a transfer it had no discretion to refuse.
cited by
242

Counts are the number of later decisions in our index that cite the case. A high count means a case has been used, not that it is good law. Nothing on this page is a citator signal and we will not show one until it is produced by reading opinions rather than counting them.

Send us this one problem. Not your whole case.

We will read it and tell you what we would do if we represented you on this single task — what we would file, on what ground, and what it would cost to have us do it.

The read is free.
If you want it written and filed, a motion to transfer venue runs $1,000 – $5,000, depending on the facts and the court. It is a discrete engagement — not a retainer, not an hourly relationship — and it ends when the motion is determined.
One name. We run conflicts before anyone here reads a word of the rest.
Optional, but it is the first thing we look at.
Plain words are fine. If you answered the questions above or dropped a document, we will add that to this for you.

Same-day answer on anything that arrives before noon Central. Or email jhenry@jhenrylaw.com with the document attached — it works exactly as well.