Patterson v. Planned Parenthood of Houston & Southeast Tex., Inc

In Patterson v. Planned Parenthood of Houston & Southeast Tex., Inc., 971 S.W.2d 439, 442 (Tex. 1998), the Court considered the parameters of the ripeness doctrine in Texas. See Patterson, 971 S.W.2d at 442-44. In Patterson, the Court noted that "ripeness, like standing, is a threshold issue that implicates subject matter jurisdiction, and like standing, emphasizes the need for a concrete injury for a justiciable claim to be presented." Patterson, 971 S.W.2d at 442. While standing focuses on the issue of who may bring an action, ripeness focuses on when that action may be brought. See Patterson, 971 S.W.2d at 442. Under the ripeness doctrine, the Courts consider whether, at the time a lawsuit is filed, the facts are sufficiently developed "so that an injury has occurred or is likely to occur, rather than being contingent or remote." Thus the ripeness analysis focuses on whether the case involves "uncertain or contingent future events that may not occur as anticipated or may not occur at all." By focusing on whether the plaintiff has a concrete injury, the ripeness doctrine allows courts to avoid premature adjudication, and serves the constitutional interests in prohibiting advisory opinions. A case is not ripe when determining whether the plaintiff has a concrete injury depends on contingent or hypothetical facts, or upon events that have not yet come to pass. Because that is the case here, the trial court did not have jurisdiction to hear this dispute.