Tx Quality Check

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name: tx-quality-check description: > Use to QC, review, or validate a Texas court document before filing. Triggers: "quality check Texas filing", "is my Texas motion ready to file", "pre-filing review Texas", "QC this Texas document", "check this petition before I file it in Texas", "validate this Texas affidavit", "audit this Texas packet", "is my Harris County motion ready", "review my Texas answer". Runs two passes plus a packet sweep: (1) format pass — caption and form, document title, Tex. R. Civ. P. 57 signature with State Bar of Texas bar number (or self-represented designation), line numbering

• footer + "Page X of Y", Tex. R. Civ. P. 21a certificate of service, and the Tex. R. Civ. P. 47(c) relief-range statement on a petition; (2) content pass — relief and grounds stated, Notice of Hearing timing, verified denial where required, affirmative defenses pleaded, required attachments including the proposed order. Lighter touch than tx-fact-check, which deep-dives evidentiary citations and sworn-vs-argued alignment. version: 0.1.0

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Texas Pre-Filing Quality Check

NOT LEGAL ADVICE. This skill detects errors in form and structural completeness — it verifies the surface. It does not assess whether the underlying legal position is sound. Verify against the current Texas Rules of Civil Procedure and the local rules of the filing court before filing.

Use this skill as the last step before filing any Texas court document. Two passes, plus a packet-consistency sweep.

A note on the forum

Confirm the court level before the format pass — District Court, County Court at Law / Constitutional County Court, or Justice Court (JP). Caption wording and judge title differ, and justice-court procedure is simplified: under Tex. R. Civ. P. 500.3(e) the regular rules of civil procedure and the rules of evidence largely do not apply in justice court except where TRCP Part V (Rules 500–510) incorporates them. Route family-law filings to tx-family-court for the matching caption and the Petitioner/Respondent designations (rather than Plaintiff/Defendant).

Pass 1 — Format

For a generated filing, run scripts/format-check.py first:

python3 plugins/tx-court-docs/scripts/format-check.py path/to/filing.docx

The format-check script validates the marketplace common-practice defaults (line numbering, footer, "Page X of Y", caption, signature) against the Texas baseline. Where a value is a local-rule matter, the script emits WARN (not FAIL) — resolve those by checking the venue's local rules. Resolve any FAIL before continuing.

Format pass — non-.docx (markdown / text drafts)

Verify manually:

• Caption — names of the parties, the court (e.g., "In the [Nth] Judicial District Court of [County] County, Texas"), party designations (Plaintiff/Defendant; Petitioner/Respondent in family/special matters), the cause number, and the document title
• Pleading form (Tex. R. Civ. P. 45 / 47) — a plain statement of the cause of action; numbered paragraphs; and, on a petition, the Tex. R. Civ. P. 47(c) statement of the range of relief sought (a Texas requirement — its omission can bar a default judgment)
• Motion form (Tex. R. Civ. P. 21) — states the grounds and the relief sought; "TO THE HONORABLE JUDGE" opener; PRAYER closes
• Notice of Hearing (Tex. R. Civ. P. 21) — present where a motion is being set; submission vs. oral hearing chosen; the notice floor (or the Rule 166a 21-day track) confirmed
• Signature block (Tex. R. Civ. P. 57) — name, address, telephone, email, fax, and State Bar of Texas bar number if an attorney, or the pro se / self-represented designation if not
• Certificate of Service (Tex. R. Civ. P. 21a) — date, manner of service, and each recipient (and the eFileTexas e-service confirmation where e-filed)
• Line numbering + footer present with "Page X of Y" and the document title
• Sensitive-data handling — confirm the redaction practice (e.g., truncating Social Security and financial-account numbers) before filing

Pass 2 — Content

The content check applies the pro-se drafting framework. Citation resolution is delegated to tx-fact-check; this pass confirms the component is structurally complete.

For a motion:

• Relief stated clearly in the opening paragraph (Rule 21)
• Grounds stated for the relief
• Rule or statute citation that grants the relief (e.g., Tex. R. Civ. P. 166a summary judgment; Rule 91a dismissal; CPRC § ___)
• Numbered factual paragraphs with record cites (affidavit/ declaration ¶, petition ¶, exhibit, admission)
• Application of controlling Texas authority — case law applied to the facts (citations verified by tx-fact-check)
• Counter-arguments addressed
• PRAYER — what exactly should the court do?
• Notice of Hearing prepared with the Rule 21(b) notice floor (or Rule 166a 21-day track), consistent with tx-deadlines
• For Rule 166a(i) no-evidence: the specific elements with no evidence are stated
• For Rule 91a: filed within 60 days of the challenged pleading; rests on the pleadings only
• Proposed order drafted as a separate document (tx-draft-order)

For a petition:

• Tex. R. Civ. P. 47(c) statement of relief range present
• Discovery control plan level stated (Tex. R. Civ. P. 190 — Level 1/2/3; expedited actions under Rule 169)
• Jurisdiction and venue alleged
• Numbered paragraphs; plain statement of each cause of action
• PRAYER for relief; request for citation to issue

For an affidavit / unsworn declaration:

• Personal-knowledge foundation in the opening paragraph
• Numbered factual paragraphs — facts only, no argument
• Exhibit references match the attached exhibits
• Jurat (notarized affidavit) or a CPRC § 132.001 unsworn declaration under penalty of perjury (no notary), with the prescribed jurat (printed name, date of birth, address, county and state of execution)
• For a business-records affidavit, the custodian / qualified-witness foundation under Tex. R. Evid. 902(10)

For a proposed order / judgment:

• Caption identical to the underlying motion
• Recitals separate from the decretal clause ("IT IS ORDERED")
• Decretal clause mirrors the motion's PRAYER, item by item
• A final judgment disposes of all parties and all claims (or the interlocutory status is intended and clear)
• Judge signature / "SIGNED this ___ day" line at the foot; "submitted by" line; transmittal consistent with tx-submit-order

For an Original Answer:

• General denial (Tex. R. Civ. P. 92) and/or specific denials
• Verified denial under oath where Tex. R. Civ. P. 93 requires it (e.g., denial of a sworn account under Rule 93(10) / Rule 185, lack of capacity, defect of parties) — an unverified denial may fail to put the matter in issue
• Affirmative defenses pleaded (limitations, payment, lack of standing, etc.) — defenses not pleaded may be waived
• Compulsory counterclaims stated (Tex. R. Civ. P. 97)
• Timeliness — answer deadline confirmed against the return of service via tx-deadlines (the Rule 99 "Monday rule" in district/county court; the end of the 14th day after service in justice court under Rule 502.5)

Pass 3 — Packet consistency

If filing a packet (petition/motion + proposed order + Notice of Hearing + affidavit/declaration + certificate of service + civil case information sheet):

• Same caption across all documents — court, county, party names, cause number
• Same document title referenced in the certificate of service, the Notice of Hearing, and the proposed order
• Dates align — certificate-of-service date matches the signature date; affidavit jurat / declaration date consistent; hearing/submission date respects the notice floor
• Relief sought matches between motion (PRAYER) and proposed order (item by item)
• All referenced exhibits attached

Pre-flight checklist

Check	Done
Forum confirmed (District / County Court at Law / Justice Court)	☐
scripts/format-check.py run; no FAIL (WARN items confirmed against local rules)	☐
Caption shows court, county, party designations, cause number	☐
Pleading/motion form correct; petition carries the Rule 47(c) relief range	☐
Notice of Hearing meets the notice floor (or Rule 166a 21-day track)	☐
Signature block has State Bar of Texas number (attorney) or self-represented designation (Rule 57)	☐
Certificate of Service shows manner, date, recipients (Rule 21a)	☐
Footer carries document title + "Page X of Y"	☐
Verified denial filed where Rule 93 requires it (answer)	☐
Affirmative defenses pleaded (answer)	☐
Final judgment disposes of all parties and claims	☐
Proposed order prepared as a separate document	☐
tx-fact-check deep audit run (if high-stakes filing)	☐

Common Texas pre-filing failures

1. Missing Tex. R. Civ. P. 47(c) relief-range statement on a petition — can bar a default judgment.
2. Unverified denial of a sworn account — Tex. R. Civ. P. 93(10) / Rule 185 require a denial under oath; a bare general denial does not put a properly verified account in issue.
3. No-evidence motion that fails to state the specific elements — Tex. R. Civ. P. 166a(i) requires the motion to identify the elements on which there is no evidence.
4. Notice of Hearing short of the notice floor (or the Rule 166a 21-day track) once the +3-day mail/email add-on is counted.
5. Missing State Bar of Texas number or self-represented designation in the Tex. R. Civ. P. 57 signature block.
6. A "final" judgment that does not dispose of all parties and claims — it is interlocutory and generally not appealable.

Composition

• For the deep evidentiary-citation and sworn-vs-argued review: tx-fact-check
• For the format baseline (caption / Rule 21 / Rule 57 / Rule 21a): tx-statewide-format
• For drafting each component: tx-draft-motion, tx-draft-declaration, tx-draft-note, tx-draft-order
• For deadline arithmetic (notice floor, Rule 166a 21-day track, mail add-on, the Rule 99 "Monday rule"): tx-deadlines
• For the forum/venue: tx-hcdc, tx-dcdc, tx-county-courts, tx-family-court
• For the final filing step (eFileTexas assembly): tx-file-packet

References to author

• references/format-checklist.md — the format pass expanded
• references/content-checklist.md — the per-document-type content pass expanded