In Ex parte Rieck, 144 S.W.3d 510, 519 (Tex. Crim. App. 2004) the court considered how to characterize an inmate's habeas application complaining about the time credit consequences of his parole revocation. Although the issue in that case was whether an application for habeas relief can be considered a "lawsuit" for purposes of government code section 498.0045, Tex. Gov't Code Ann. 498.0045 (Vernon Supp. 2010) (requiring the forfeiture of an inmate's good conduct time if an inmate files a lawsuit that is dismissed as frivolous, but not addressing whether it should be characterized as civil or criminal), the court did discuss the trouble with characterizing applications for habeas relief. Rieck, 144 S.W.3d at 515-16. The court observed that "most jurisdictions have traditionally regarded habeas corpus as a civil remedy, even when the relief sought is from confinement in the criminal justice system" but that "courts have struggled with how to characterize habeas proceedings and have sometimes characterized them as 'neither civil nor criminal but rather sui generis.'" Id. It noted that the United States Supreme Court has acknowledged the characterization of habeas corpus proceedings as civil but has also referred to that label as "gross and inexact" and has stated that "essentially, the proceeding is unique." Id. at 516. The court of criminal appeals also noted that "Texas has gone further in eschewing the civil label for habeas proceedings arising from criminal prosecutions or convictions. Such proceedings are categorized as 'criminal' for jurisdictional purposes and the Texas Rules of Civil Procedure do not ordinarily apply. Article 11.07 habeas proceedings are categorized as criminal proceedings by statute." Id. The court ultimately held that a habeas proceeding under code of criminal procedure article 11.07 is not a "lawsuit" for purposes of government code section 498.0045. Id. at 521.