Texas Civil Law Time Limits

    A practical calendaring guide for Texas civil litigators. This page collects common Texas civil deadlines that affect day-to-day calendaring.

    By Bryan C. Holman

    Important Practice Note

    Texas procedure is judge-driven. A docket control order can shorten or expand many dates. Always calendar the rule-based deadline and any scheduling-order deadline that is earlier. This page provides general information for calendaring — it is not legal advice and may not reflect the latest rule amendments, local rules, or standing orders.

    Quick Navigation

    Statutes of Limitations (Tex. Civ. Prac. & Rem. Code Ch. 16)

    Unlike some jurisdictions, Texas does not have a single fixed time for all civil cases. Chapter 16 sets specific limitations for particular causes of action.

    Defamation (Libel / Slander)

    Tex. Civ. Prac. & Rem. Code § 16.002

    1 Year

    Personal Injury / Property Damage / Wrongful Death

    Tex. Civ. Prac. & Rem. Code § 16.003(a)

    Accrues on date of injury or death. Note tolling exceptions for minors and the discovery rule.

    2 Years

    Medical / Health-Care Liability

    Tex. Civ. Prac. & Rem. Code § 74.251; Ch. 74

    Possible 10-year statute of repose under certain conditions.

    2 Years

    Breach of Written Contract

    Tex. Civ. Prac. & Rem. Code § 16.004

    4 Years

    Fraud

    Tex. Civ. Prac. & Rem. Code § 16.004

    4 Years

    Breach of Fiduciary Duty

    Tex. Civ. Prac. & Rem. Code § 16.004

    4 Years

    Debt Collection / Suit on Account

    Tex. Civ. Prac. & Rem. Code § 16.004

    4 Years

    Trespass to Try Title (Real Property)

    Tex. Civ. Prac. & Rem. Code §§ 16.024–16.028

    Varies by type of adverse-possession claim.

    3–25 Years

    Construction Defects (Statute of Repose)

    Tex. Civ. Prac. & Rem. Code § 16.009

    From substantial completion of the improvement.

    10 Years

    Child Sexual Abuse

    Tex. Civ. Prac. & Rem. Code § 16.0045

    Extended limitations period under current Texas law.

    15 Years

    DTPA Claims

    Tex. Bus. & Com. Code § 17.565

    Accrues when consumer knew or should have known of the deceptive act.

    2 Years

    Insurance Code Violations (Unfair Settlement Practices)

    Tex. Ins. Code § 541.162

    2 Years

    UCC / Sale of Goods

    Tex. Bus. & Com. Code § 2.725

    Parties may reduce by agreement to not less than one year.

    4 Years

    Service of Process & Answers

    Texas does not use a "60 days after filing" service rule. The key practical rule is diligence in service — lack of diligence can defeat limitations even if you filed on time.

    Answer Deadline (District / County Courts at Law)

    Tex. R. Civ. P. 99(b)

    Defendant must answer by 10:00 a.m. on the Monday next after 20 days from service.

    Monday after 20 days

    Return / Proof of Service

    Tex. R. Civ. P. 107

    Calendar immediately upon receipt. Defective returns can create default-judgment problems.

    Promptly

    Substituted Service (if personal service unsuccessful)

    Tex. R. Civ. P. 106

    Available when personal service has been unsuccessful.

    By Court Order

    Initial Disclosures (Texas Rule 194)

    Texas requires initial disclosures in most civil cases. This deadline drives discovery planning.

    Initial Disclosures

    Tex. R. Civ. P. 194.2(a)

    Due within 30 days after the filing of the first answer or general appearance, unless a different time is set by the court.

    30 Days

    Written Discovery Deadlines (Texas Rules 192–215)

    Texas discovery timing is controlled by the discovery control plan (Level 1, 2, or 3) and rule-based response deadlines.

    Responses to Interrogatories, RFPs, and RFAs

    Tex. R. Civ. P. 193.2(a)

    Calendar separate deadlines for each set received. Also calendar for privilege logs and production timing.

    30 Days

    Objections to Written Discovery

    Tex. R. Civ. P. 193.2(a), (e)

    Objections must be made within the response time or are commonly treated as waived, subject to limited exceptions.

    30 Days (same window)

    Motions to Compel / Discovery Sanctions

    Tex. R. Civ. P. 215

    Motion-and-conference driven. Governed by Rule 215 and the court's scheduling order.

    Per Court Order

    Discovery Period Cutoffs (Level 2 Cases)

    Most Texas cases are under Level 2 discovery. The discovery "end date" is one of the most important dates to calendar early.

    Level 2 Discovery Period Ends

    Tex. R. Civ. P. 190.3(b)(1)

    Ends at the earlier of: (1) 30 days before trial, or (2) nine months after initial disclosures are due. Re-calendar every time the trial date moves — a new setting can change which prong controls.

    Earlier of 2 prongs

    Depositions & Subpoenas

    Texas deposition practice turns on "reasonable notice," subpoena compliance deadlines, and quick objections when needed.

    Deposition Notice

    Tex. R. Civ. P. 199

    No fixed minimum in the rules; local practice often dictates a practical standard. Calendar the notice date, production date, and compliance date.

    Reasonable Notice

    Subpoena Compliance / Production

    Tex. R. Civ. P. 176

    Must allow reasonable time for compliance.

    Per Subpoena

    Objections / Motions to Quash Subpoenas

    Tex. R. Civ. P. 176.6(d)

    Must be made in writing before the time specified for compliance.

    Before compliance date

    Motions for Summary Judgment (Texas Rule 166a)

    Texas summary judgment timing is rigid and frequently enforced.

    Motion Filing & Service Before Hearing

    Tex. R. Civ. P. 166a(c)

    A traditional motion must be filed and served at least 21 days before the hearing.

    21 Days

    Response / Opposing Evidence

    Tex. R. Civ. P. 166a(c)

    Absent leave, the nonmovant must file and serve opposing affidavits or other written response materials no later than 7 days before the hearing.

    7 Days Before Hearing

    Note: Texas rules have been updated in recent years. Confirm the current text of Rule 166a and your court's standing order if using a modern briefing schedule.

    Claims Against Government Entities (Texas Tort Claims Act)

    Government cases have early notice traps. Calendar governmental notice deadlines on day one of case intake.

    Notice of Claim (General TTCA Rule)

    Tex. Civ. Prac. & Rem. Code § 101.101(a)

    Must reasonably describe the damage, time and place, and incident. Due no later than 6 months after the incident.

    6 Months

    City Charter Notice (May Be Shorter)

    Tex. Civ. Prac. & Rem. Code § 101.101(b)

    City charter and ordinance provisions may impose shorter deadlines. Investigate the specific entity's notice rules immediately.

    60–90 Days (varies)

    Best Practice: Treat governmental notice as an "immediate" deadline. Investigate the specific entity's notice rules the day the file comes in. Failure to timely present a claim can bar the cause of action entirely.

    UM/UIM Claims

    UM/UIM limitation and accrual can be fact-dependent. A common Texas framing is that UM/UIM suits often proceed under a contractual limitations analysis.

    Calendar these dates: (1) the crash date, (2) any denial date, (3) policy notice deadlines, and (4) any suit-limitation clauses in the policy.

    Debt Collection / Time-Barred Debts

    Suit on Account or Debt

    Tex. Civ. Prac. & Rem. Code § 16.004

    Texas imposes a four-year statute of limitations on many debt collection actions.

    4 Years

    Calendaring Best Practices

    Statute of Limitations

    Start from the date the cause of action accrues. Note any tolling exceptions (e.g., minor plaintiffs, discovery rule).

    Service Deadlines

    Texas requires diligence. Calendar service-related milestones to ensure service occurs within limitations.

    Discovery Windows

    Calendar response windows for each set received. Later trial settings shift the discovery cutoff — re-calendar accordingly.

    Summary Judgment

    Calendar both the motion deadline (21 days) and response deadline (7 days) based on the hearing date.

    Government Claims

    Journal all notice deadlines immediately on intake. These are often the shortest and most unforgiving deadlines.

    Docket Control Orders

    Always calendar the rule-based deadline AND any scheduling-order deadline that is earlier. The court's order controls when stricter.

    Disclaimer

    This page provides general information for calendaring and case management. It is not legal advice, and it may not reflect the latest rule amendments, local rules, standing orders, or your court's scheduling order. If you need advice for a specific case, you should consult counsel.

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