Knowlton v. United States Brass Corp

In Knowlton v. United States Brass Corp., 864 S.W.2d 585, 598 (Tex. App.--Houston 1st Dist. 1993), aff'd in part and rev'd in part on other grounds, 919 S.W.2d 644, 39 Tex. Sup. Ct. J. 351 (Tex. 1996), the Houston court determined that the "time of submission" had passed after objections were made to the charge, after the charge was read to the jury, after closing arguments, and after the trial court recessed the proceedings, but before the jury began deliberating. Although the Houston court does not indicate the exact time in this sequence when submission occurred, we hold that for purposes of Section 33.014, the "issues of the action are submitted to the trier of fact" after closing arguments are completed. To hold otherwise would ignore the purpose of closing argument which is to assimilate the evidence to assist the jury in drawing proper conclusions from the evidence.