Narrowing Interlocutory Venue Appeals in Multi‑Plaintiff Cases:
Rush Truck Centers of Texas, L.P. & Blue Bird Body Co. v. Sayre

I. Introduction

In Rush Truck Centers of Texas, L.P. and Blue Bird Body Company v. Sean and Tori Sayre, the Supreme Court of Texas resolved a deep and recurring conflict among the courts of appeals over interlocutory review of venue decisions when a lawsuit has multiple plaintiffs.

The case arises from a catastrophic school-bus accident that killed six-year-old Emory Sayre in Parker County, Texas. Her parents, Sean and Tori, sued the bus dealer (Rush Truck Centers) and the manufacturer (Blue Bird) in Dallas County. After the trial court denied a motion to transfer venue, the defendants took an interlocutory appeal; the Dallas Court of Appeals affirmed and reached the merits of where venue properly lay.

The Supreme Court, however, never reached the merits. Instead, it held that the court of appeals lacked jurisdiction to entertain an interlocutory venue appeal under the Texas venue statutes. The Court construes Texas Civil Practice and Remedies Code § 15.003(b) narrowly:

Interlocutory appeals of venue determinations in multi-plaintiff cases are permitted only when a trial court actually resolves whether a particular plaintiff has independently established venue under § 15.003(a).
The mere fact that a case involves multiple plaintiffs does not, by itself, create a right to an interlocutory venue appeal.

Because Sean and Tori Sayre asserted identical claims on identical facts and relied on identical venue grounds, the trial court had no need to make distinct “independent venue” determinations under § 15.003(a). Consequently, the appellate court had no jurisdiction under § 15.003(b). The Supreme Court vacated the court of appeals’ judgment and remanded to the trial court.

This decision significantly reshapes Texas interlocutory practice in venue disputes and closes what the Court describes as a “gaping jurisdictional loophole” that had developed in the courts of appeals.

II. Factual and Procedural Background

A. The Underlying Tragedy

In April 2022, six-year-old Emory Sayre was struck and killed by her school bus as she exited and crossed in front of it near her home in Parker County, Texas. The bus:

was manufactured by Blue Bird Body Company in Georgia; and
was sold to Brock Independent School District by Rush Truck Centers of Texas, L.P., an authorized Blue Bird dealer.

Rush Truck’s principal office is in Comal County. At the relevant time it also operated a facility in Dallas County known as “Rush Bus Centers of Dallas” (RBC–Dallas).

B. The Lawsuit and Venue Choices

In September 2022, Emory’s parents, Sean and Tori Sayre:

filed suit in Dallas County against Rush Truck, Blue Bird, and Brock ISD;
later nonsuited Brock ISD; and
proceeded against Rush Truck and Blue Bird on multiple products-liability and negligence theories.

The Sayres pleaded numerous strict-liability and negligence-based claims against both defendants, including design and manufacturing defect, failure to warn, negligence, and gross negligence.

They asserted venue in Dallas County under § 15.002(a)(1) of the Civil Practice and Remedies Code, which permits venue in:

“a county in which all or a substantial part of the events or omissions giving rise to the claim occurred.”

According to the Sayres, at Rush Truck’s Dallas County location the company:

proposed, negotiated, and entered into the sales agreement for the bus;
issued billing for the bus;
registered the bus;
inspected the bus; and
passed title to Brock ISD.

Under § 15.005 (multiple defendants), if venue was proper in Dallas County as to Rush Truck, it would also be proper as to Blue Bird.

C. Defendants’ Motion to Transfer Venue

Rush Truck and Blue Bird moved to transfer venue to:

Parker County (where the accident occurred and where the employee who negotiated the sale worked from home and where the bus was delivered), or
Comal County (where Rush Truck’s principal office is located).

They characterized the Dallas County activities as merely clerical or administrative, contending that the “heart of the dispute” was in Parker County, where the accident and core interactions occurred.

The trial court denied the motion to transfer venue.

D. Interlocutory Appeal and Court of Appeals Decision

Rush Truck and Blue Bird brought an interlocutory appeal. The Dallas Court of Appeals:

held that it had jurisdiction to hear an interlocutory appeal of the venue ruling because the case involved multiple plaintiffs; and
on the merits, affirmed the trial court’s refusal to transfer venue, concluding that a “substantial part of the events” giving rise to the claim occurred in Dallas County, including most activities related to the “supply” of the bus. See Rush Truck Ctrs. of Tex., L.P. v. Sayre, 704 S.W.3d 857 (Tex. App.—Dallas 2023).

E. Supreme Court Review Focuses on Jurisdiction

Rush Truck and Blue Bird petitioned for review, arguing that the court of appeals misapplied the venue statutes by focusing on administrative activities in Dallas County instead of where the core events occurred.

After full briefing on the venue merits, the Supreme Court invoked its authority to review jurisdictional issues sua sponte and requested supplemental briefing on whether the court of appeals had jurisdiction to entertain the interlocutory appeal at all. See Abbott v. Mexican American Legislative Caucus, Texas House of Representatives, 647 S.W.3d 681, 699 (Tex. 2022).

The Supreme Court ultimately resolved the case solely on jurisdictional grounds.

III. Summary of the Opinion

A. Core Holding

The Supreme Court holds:

The mere presence of multiple plaintiffs does not suffice to invoke appellate jurisdiction for an interlocutory appeal of a venue ruling under § 15.003(b). That statute permits interlocutory appeals only when the trial court makes a determination “under Subsection (a)” as to whether a given plaintiff has independently established proper venue.

Because Sean and Tori Sayre asserted:

identical claims,
based on identical facts, and
on identical venue grounds,

the trial court had no occasion to decide whether one parent could independently establish proper venue apart from the other. There was no “independent venue” determination under § 15.003(a). Thus:

§ 15.003(b) did not apply,
§ 15.064(a)’s general bar on interlocutory appeals of venue rulings controlled, and
the court of appeals lacked jurisdiction to hear the interlocutory appeal.

B. Disposition

The Supreme Court:

vacated the judgment of the court of appeals, and
remanded the case to the district court for further proceedings, without deciding whether Dallas, Parker, or Comal County is the proper venue on the merits.

IV. Detailed Analysis

A. Statutory Framework: Venue and Interlocutory Appeals

1. General rule: final judgment and no interlocutory appeals from venue rulings

Texas courts of appeals generally have jurisdiction only over appeals from final judgments. See Lehmann v. Har–Con Corp., 39 S.W.3d 191, 195 (Tex. 2001). Venue determinations are ordinarily unreviewable until final judgment.

Section 15.064(a) codifies a clear rule specific to venue:

“The court shall determine venue questions from the pleadings and affidavits. No interlocutory appeal shall lie from the determination.”

This is a strong textual prohibition against piecemeal appellate review of venue decisions.

2. Section 15.003: multi‑plaintiff cases and the “tag‑along” problem

Section 15.003 addresses suits with multiple plaintiffs. Under § 15.003(a):

“In a suit in which there is more than one plaintiff, … each plaintiff must, independently of every other plaintiff, establish proper venue. If a plaintiff cannot independently establish proper venue, that plaintiff's part of the suit … must be transferred … or dismissed, unless that plaintiff, independently of every other plaintiff, establishes” the four factors listed in § 15.003(a)(1)–(4).

These provisions are designed to prevent “tag‑along” venue—that is, situations in which:

one plaintiff can properly sue in County X,
other plaintiffs have no legitimate connection to County X, but
they attempt to piggyback on the first plaintiff’s venue to remain there.

The four factors in § 15.003(a)(1)–(4) provide a narrow escape hatch allowing a plaintiff who cannot independently establish venue to stay if specific joinder and fairness criteria are met.

3. Section 15.003(b): the narrow interlocutory-appeal exception

Section 15.003(b) creates an exception to the no-interlocutory-appeal rule in § 15.064(a), but only in carefully circumscribed circumstances:

“An interlocutory appeal may be taken of a trial court's determination under Subsection (a) that:

a plaintiff did or did not independently establish proper venue; or

a plaintiff that did not independently establish proper venue did or did not establish the items prescribed by Subsections (a)(1)-(4).

Thus, the statutory text ties the availability of interlocutory appeal to a specific kind of trial-court ruling: a determination under Subsection (a) about independent venue (or the four-factor exception).

B. The Competing Interpretations of § 15.003(b)

1. Majority view in the courts of appeals

Before Rush Truck, most Texas courts of appeals had read § 15.003(b) broadly. They held that in any case with multiple plaintiffs, a trial court’s venue ruling was immediately appealable. Under this approach:

the mere presence of more than one plaintiff triggered § 15.003(b); and
courts did not require that the trial court have made a specific independent-venue determination as to any particular plaintiff.

The opinion cites a series of decisions adopting this expansive view, including:

Shamoun & Norman, LLP v. Yarto Int'l Grp., 398 S.W.3d 272 (Tex. App.—Corpus Christi–Edinburg 2012, pet. dism'd);
Ryan Marine Servs., Inc. v. Hoffman, 668 S.W.3d 171 (Tex. App.—Houston [1st Dist.] 2023, no pet.);
Clear Diamond, Inc. v. Zapata, No. 03-20-00057-CV, 2021 WL 3572725 (Tex. App.—Austin Aug. 13, 2021, no pet.);
Flare Air, L.L.C. v. Burton, No. 06-18-00097-CV, 2019 WL 166834 (Tex. App.—Texarkana Jan. 11, 2019, no pet.);
Brown v. Health & Med. Prac. Assocs., Inc., No. 09-13-00192-CV, 2013 WL 5658605 (Tex. App.—Beaumont Oct. 17, 2013, no pet.);
In re AAA Bros. Holdings, LLC, No. 12-23-00210-CV, 2023 WL 6631952 (Tex. App.—Tyler Oct. 11, 2023, orig. proceeding [mand. denied]);
and others.

These courts generally reasoned that the more specific statute (§ 15.003(b)) allowing certain interlocutory appeals “trumped” the more general bar in § 15.064(a) whenever multiple plaintiffs were involved.

2. The Fourth Court of Appeals’ narrower approach

The Fourth Court of Appeals (San Antonio) diverged. In Basic Energy Servs. GP, LLC v. Gomez, 398 S.W.3d 734 (Tex. App.—San Antonio 2010, no pet.), and Harding Bars, LLC v. McCaskill, 374 S.W.3d 517 (Tex. App.—San Antonio 2012, pet. denied), it held that:

§ 15.003(b) allows interlocutory appeals only “to plaintiffs who are unable to independently establish venue apart from the joinder factors” in § 15.003(a).

In other words, the right to an interlocutory venue appeal is limited to disputes over whether a particular plaintiff:

has independently established venue, or
has satisfied the four-factor joinder test in § 15.003(a)(1)-(4).

If all plaintiffs share the same venue facts and grounds, and there is no controversy over independent venue, § 15.003(b) does not apply.

3. The parties’ positions in this case

Defendants’ view (Rush Truck & Blue Bird): They embraced the majority approach, arguing that § 15.003(b) provides interlocutory jurisdiction whenever there are multiple plaintiffs. They pointed to the “specific controls general” canon, claiming § 15.003(b) should override § 15.064(a) in multi-plaintiff cases.
Plaintiffs’ view (the Sayres): They argued, in line with the Fourth Court of Appeals, that § 15.003(b) applies only when the trial court actually makes a § 15.003(a) determination on independent venue. Because their claims and venue grounds were identical, they contended, no such determination was necessary, and thus no interlocutory appeal lay.

C. Textual Analysis: The Meaning of “Determination under Subsection (a)”

The Supreme Court’s analysis turns on the phrase “determination under Subsection (a)” in § 15.003(b). The Court’s reasoning operates in several steps:

Plain language: The text does not say “in any case with more than one plaintiff,” nor does it say “any venue determination in a multi-plaintiff suit.” Instead, it narrowly authorizes appeals of “a trial court’s determination under Subsection (a)” on specified questions of independent venue.
Cross-reference structure: By cross-referencing “Subsection (a),” the Legislature tied § 15.003(b)’s appellate jurisdiction to the mechanisms in § 15.003(a)—namely, whether each plaintiff has independently established venue, and if not, whether that plaintiff meets the four-factor exception.
Reconciliation with § 15.064(a): The Court rejects the argument that the specific (15.003(b)) automatically trumps the general (15.064(a)). Citing Scalia & Garner, it notes that the general/specific canon applies when provisions truly conflict and are irreconcilable. Here, the two sections can be harmonized:
- § 15.064(a): no interlocutory appeals from venue determinations as a broad rule;
- § 15.003(b): a narrow exception in a precisely defined subset of multi-plaintiff cases—when independent venue is disputed and decided under § 15.003(a).
Interpretation consistent with venue purpose: If § 15.003(b) were read to authorize interlocutory appeals in any multi-plaintiff case, it would “effectively swallow the rule in § 15.064(a).” The Legislature’s evident intent to limit piecemeal appeals would be undermined.

Accordingly, the Court holds that § 15.003(b) does not grant a blanket right to interlocutory appeal whenever more than one plaintiff is present; it applies only when a specific plaintiff’s independent venue status is at issue and has been resolved by the trial court under § 15.003(a).

D. Legislative Response to American Home Products and Its Limits

The Court situates § 15.003(b) within its legislative history, focusing on American Home Prods. Corp. v. Clark, 38 S.W.3d 92 (Tex. 2000).

1. American Home Products and the prior version of § 15.003

In American Home Products, the Court interpreted an earlier version of § 15.003, which:

addressed joinder/intervention of plaintiffs in multi-plaintiff suits, and
allowed interlocutory appeals only of decisions granting or denying such joinder/intervention.

The Court held that under that earlier statute:

interlocutory appeals were limited to joinder/intervention rulings; and
venue determinations under § 15.002 (the general venue statute) remained non-appealable until final judgment, even in multi-plaintiff cases.

It expressly rejected a reading that would make “any trial court venue decision under § 15.002 in a multi-plaintiff case reviewable by interlocutory appeal.” Such a reading would conflict with § 15.064’s prohibition.

2. The 2003 amendment to § 15.003

In 2003, the Legislature amended § 15.003. The amendment:

expanded § 15.003(b) to allow interlocutory appeals not only of joinder/intervention rulings but also of whether “a plaintiff did or did not independently establish proper venue,” and whether a plaintiff met the four-factor exception in § 15.003(a)(1)-(4); but
retained the requirement that the ruling being appealed be a “determination under Subsection (a).”

The Supreme Court reads the 2003 amendment as a targeted legislative response aimed at:

strengthening the enforcement of the “no tag‑along venue” rule by allowing immediate review of independent-venue determinations; but
not transforming § 15.003 into a general vehicle for interlocutory review of all venue rulings in multi-plaintiff cases.

The Court underscores that § 15.003 “is still ‘not a venue statute’” in the sense of governing where venue lies generally. Rather, it is a joinder-and-venue enforcement mechanism focused on multi-plaintiff suits.

Crucially, the Legislature did not repeal § 15.064(a) or broadly authorize interlocutory appeals of multi-plaintiff venue decisions. The retention of § 15.064(a) supports the Court’s narrow interpretation.

E. The Tag‑Along Plaintiff Concern and Its Absence Here

The Court frames § 15.003 as a safeguard against “tag‑along” plaintiffs:

plaintiffs lacking any legitimate connection to the chosen forum,
who attempt to remain in a venue solely because another plaintiff can properly sue there.

American Home Products itself involved a classic example: eleven plaintiffs suing over the same product, but only one resided in the county of suit.

By requiring that each plaintiff “independently” establish proper venue or meet the four § 15.003(a)(1)-(4) factors, the statute forces courts to police tag‑along plaintiffs and, if necessary, transfer or dismiss their claims.

In the Sayre case, however, this concern does not exist:

Both plaintiffs (Sean and Tori) are parents of the same deceased child.
They assert the same wrongful-death and survival claims, predicated on the same underlying factual event (Emory’s death) and the same alleged defects and failures relating to the bus.
They rely on the same acts or omissions to establish venue in Dallas County.

As the Court notes, the venue analysis would be identical if Emory had only one surviving parent. There is no scenario in which one parent is “tag‑along” with a different venue profile. Thus:

the trial court did not need to examine whether Sean could independently establish venue apart from Tori or vice versa; and
no “independent venue” determination arose under § 15.003(a).

Because the statutory trigger for § 15.003(b) (a determination under § 15.003(a)) is absent, the case falls back within the ambit of § 15.064(a), which prohibits interlocutory appeals of venue rulings.

F. Application of Canons of Interpretation and Structural Reasoning

The Court reinforces its reading with several interpretive principles:

Strict construction of interlocutory-appeal statutes: Citing Tex. A&M Univ. Sys. v. Koseoglu, 233 S.W.3d 835, 841 (Tex. 2007), the Court reiterates that statutes authorizing interlocutory appeals must be strictly construed as narrow exceptions to the final-judgment rule.
Context and whole-statute reading: Citing Cadena Comercial USA Corp. v. Texas Alcoholic Beverage Comm’n, 518 S.W.3d 318 (Tex. 2017), and the interpretive treatise by Scalia & Garner, the Court emphasizes that provisions must be read in the “context and framework of the entire statute.” Words like “determination under Subsection (a)” must be given effect in light of the larger structure of §§ 15.003 and 15.064.
General/specific canon correctly applied: The Court notes that the general/specific canon does not license courts to disregard harmonizable provisions. Because §§ 15.003(b) and 15.064(a) can be reconciled—by treating 15.003(b) as a narrow exception linked to § 15.003(a) determinations—the canon does not justify reading 15.003(b) as a sweeping override.

G. The Court’s Treatment of Prior Authorities

1. Jurisdictional primacy: Steel Co. and Abbott v. MALC

The Court begins by noting its obligation to address jurisdiction before merits, echoing:

Steel Co. v. Citizens for a Better Environment, 523 U.S. 83 (1998), and
Abbott v. Mexican American Legislative Caucus, Texas House of Representatives, 647 S.W.3d 681 (Tex. 2022).

It reaffirms that it “always has jurisdiction to determine its own, and the lower courts’, jurisdiction” and that courts may not reach the merits if jurisdiction is lacking.

2. Final-judgment rule: Lehmann v. Har–Con Corp.

Lehmann is cited to restate the default rule that appellate jurisdiction extends only to final judgments, providing the backdrop against which interlocutory-appeal statutes are interpreted as exceptions.

3. Strict construction of interlocutory statutes: Koseoglu

Koseoglu is invoked for the principle that statutes authorizing interlocutory appeals must be strictly construed. This supports reading § 15.003(b) narrowly, rather than as a broad license for appeals in all multi-plaintiff cases.

4. American Home Products as foundation

As discussed above, American Home Products is critical for:

identifying the legislative mischief (tag‑along plaintiffs) that § 15.003 was aimed at; and
demonstrating the Court’s earlier insistence that § 15.003 was not a general venue statute and could not override § 15.064(a) to make all multi-plaintiff venue rulings interlocutorily appealable.

5. The Fourth Court of Appeals’ decisions: Basic Energy and Harding Bars

The Court expressly approves the Fourth Court’s approach in:

Basic Energy Servs. GP, LLC v. Gomez, 398 S.W.3d 734 (Tex. App.—San Antonio 2010, no pet.); and
Harding Bars, LLC v. McCaskill, 374 S.W.3d 517 (Tex. App.—San Antonio 2012, pet. denied).

Those cases held that § 15.003(b) interlocutory appeals are available only where a plaintiff is unable to independently establish venue without resort to the joinder factors in § 15.003(a). The Supreme Court endorses that interpretation as faithful to “the text, context, and structure” of the statute.

6. Disapproval of the majority view without naming a conflict case

While not formally “disapproving” or overruling each cited court-of-appeals case by name, the Supreme Court unmistakably rejects their expansive reading. By stating that most courts of appeals had “stretched this statutory exception into a gaping jurisdictional loophole” and then adopting the narrower interpretation, the Court effectively resolves the split in favor of the Fourth Court’s approach.

7. Other authorities: Scalia & Garner, Cadena Comercial, McClane Champions, Bridgestone/Firestone

The Court uses:

Scalia & Garner’s Reading Law to support careful application of the general/specific canon and emphasize contextual reading; and
cases like Cadena Comercial USA Corp. v. TABC, 518 S.W.3d 318 (Tex. 2017); McClane Champions, LLC v. Houston Baseball Partners LLC, 671 S.W.3d 907 (Tex. 2023); and Bridgestone/Firestone, Inc. v. Glyn–Jones, 878 S.W.2d 132 (Tex. 1994)

to underscore that statutory meaning arises from context, not isolated phrases read in a vacuum.

8. Jurisdiction-first disposition: Rattray v. City of Brownsville

Finally, the Court cites Rattray v. City of Brownsville, 662 S.W.3d 860 (Tex. 2023), for the “fundamental rule” that if any valid basis exists to defeat jurisdiction, the court may not reach the merits. This justifies ending the analysis at the jurisdictional question here.

V. Simplifying Key Legal Concepts

Venue: Venue is the particular county in which a lawsuit may be filed and tried. It is distinct from jurisdiction. Jurisdiction asks whether a court has power over the subject matter and parties; venue asks where among courts that do have jurisdiction the case should be heard.
Interlocutory Appeal: An interlocutory appeal is an appeal taken before a case has reached final judgment. Texas generally disfavors interlocutory appeals, allowing them only when statutes expressly authorize them (for example, certain immunity rulings, class-certification orders, or, here, limited venue determinations in multi-plaintiff suits).
Final-Judgment Rule: Under the final-judgment rule, appellate courts ordinarily review cases only once, after the trial court has resolved all claims against all parties. This rule promotes efficiency and prevents piecemeal appeals.
“No Interlocutory Appeal Shall Lie”: This phrase in § 15.064(a) is a categorical bar against appeals from venue rulings before final judgment, unless another section (like § 15.003(b)) provides a specific exception.
Multi‑Plaintiff Venue and “Tag‑Along” Plaintiffs: “Tag‑along” plaintiffs are those who have no factual or legal basis for suing in a particular county but join their claims to a plaintiff who does, hoping to stay in that forum. Section 15.003(a) tries to prevent that by requiring each plaintiff to show a legitimate venue connection, or else satisfy strict joinder criteria.
“Independently Establish Proper Venue”: A plaintiff independently establishes venue if, without relying on any other plaintiff, that plaintiff can show that the chosen county is a proper venue under the general venue rules (e.g., where the defendant resides, where a substantial part of the events occurred, etc.).
“Determination under Subsection (a)”: This refers to a trial court’s application of § 15.003(a) to a specific plaintiff—deciding whether that plaintiff individually has proper venue or, if not, whether that plaintiff satisfies the four-factor test allowing joinder despite lack of independent venue. Only such determinations are interlocutorily appealable under § 15.003(b).

VI. Practical and Doctrinal Impact

A. Immediate Effects on Appellate Jurisdiction

This decision sharply curtails interlocutory venue appeals in Texas multi-plaintiff cases:

Appellate courts may no longer accept interlocutory appeals solely because more than one plaintiff is named in the case.
They must examine whether the trial court actually made a § 15.003(a) determination about a specific plaintiff’s independent venue status (or the § 15.003(a)(1)-(4) factors).
If all plaintiffs share identical venue facts and grounds, there is no jurisdiction for an interlocutory appeal of a venue ruling.

B. Litigation Strategy: Plaintiffs

Venue pleadings: Plaintiffs will be mindful that if they intend to avoid early venue appeals, maintaining homogeneity among plaintiffs’ venue grounds may make it harder for defendants to obtain interlocutory review.
Joinder decisions: Plaintiffs with disparate venue connections may need to consider whether joining in a single suit risks immediate venue challenges and appeals under § 15.003(b).
Mass or multi-plaintiff torts: In large multi-plaintiff actions (e.g., product liability, toxic torts), the risk of interlocutory appeals remains if some plaintiffs lack independent venue and rely on others’ connections.

C. Litigation Strategy: Defendants

Targeted venue challenges: Defendants seeking interlocutory review must frame their venue challenges as disputes about particular plaintiffs’ independent venue (or their failure to meet the four § 15.003(a)(1)-(4) factors), not as a generalized challenge to overall venue.
Discovery and affidavits on per-plaintiff venue facts: To create a basis for an interlocutory appeal, defendants may need to develop a record distinguishing the venue connections (or lack thereof) of different plaintiffs.
Homogeneous plaintiff groups: Where plaintiffs are similarly situated—like co-owners, spouses, or parents asserting derivative claims—defendants will often be unable to obtain interlocutory review and will have to wait for final judgment to challenge venue.

D. Guidance for Trial Courts

Trial judges handling multi-plaintiff suits should:

Recognize that § 15.003(a) imposes a duty to assess each plaintiff’s independent venue status when the issue is raised.
Make clear, on the record, whether and how they have applied § 15.003(a) to any plaintiff alleged not to have independent venue.
Understand that:
- if plaintiffs’ venue facts and grounds are homogeneous, there may be no need for individualized § 15.003(a) analysis; and
- in such cases, their venue rulings will generally be immune from interlocutory review.

Clear rulings identifying which plaintiffs do or do not independently establish venue will:

facilitate appropriate interlocutory appeals when authorized; and
help prevent unnecessary or improper interlocutory appeals where § 15.003(b) does not apply.

E. Systemic Impact: Fewer Piecemeal Venue Appeals

By closing the “loophole” that allowed interlocutory appeals in virtually any multi-plaintiff case, the Court’s decision:

reduces appellate courts’ interlocutory caseload,
accelerates the path to trial or final resolution in many multi-plaintiff suits, and
aligns practice more closely with the Legislature’s intent to limit piecemeal appeals and keep litigation on a more “straight line,” as the opinion’s opening metaphor suggests.

F. Clarifying the Scope of the 2003 Amendments

Doctrinally, Rush Truck clarifies that:

the 2003 amendment to § 15.003(b) expanded, but did not revolutionize, interlocutory venue appeals;
the amendment addressed a specific concern (policing tag‑along plaintiffs), not a general dissatisfaction with the no-interlocutory-appeal rule of § 15.064(a); and
§ 15.003 remains a joinder-related statute with a focused venue-enforcement function, not a comprehensive alternative venue code.

G. Remaining Questions and Edge Cases

Several practical questions remain for future cases:

Partial overlap of venue facts: If some but not all plaintiffs share identical venue grounds, and one plaintiff’s venue connection is disputed, how detailed must the trial court’s § 15.003(a) findings be to support an interlocutory appeal?
Structuring orders: Will trial courts begin issuing more detailed, plaintiff-specific venue orders to clarify when § 15.003(b) has been triggered?
Derivative vs. independent claims: How should courts treat plaintiffs with derivative claims (e.g., loss of consortium) compared with those asserting fully independent causes of action? In many such cases, the venue facts will be identical, suggesting no 15.003(b) jurisdiction.

The opinion strongly suggests that where plaintiffs’ venue facts and legal positions are truly indistinguishable, § 15.003(b) never comes into play.

VII. Conclusion

Rush Truck Centers of Texas, L.P. & Blue Bird Body Co. v. Sayre establishes an important limitation on interlocutory venue appeals in Texas. The Court definitively holds that:

Section 15.003(b) is a narrow, targeted exception to § 15.064(a)’s broad prohibition on interlocutory appeals of venue determinations.
Interlocutory appeals are authorized only when the trial court makes a “determination under Subsection (a)” about a particular plaintiff’s independent venue status or the four-factor exception in § 15.003(a)(1)-(4).
The presence of multiple plaintiffs, standing alone, does not create appellate jurisdiction.

By aligning with the Fourth Court of Appeals’ reading in Basic Energy and Harding Bars and rejecting the expansive approach adopted by most other courts of appeals, the Supreme Court restores § 15.064(a) to its rightful prominence, curbing piecemeal venue appeals and reinforcing the final-judgment rule.

The decision clarifies the role of § 15.003 as a precise tool to combat tag‑along venue abuse, not a general authorization of interlocutory review in all multi-plaintiff cases. It provides concrete guidance for litigants and trial courts on how to structure, litigate, and review venue disputes involving multiple plaintiffs, while respecting the Legislature’s foundational choice to make venue rulings generally unreviewable until final judgment.

Narrowing Interlocutory Venue Appeals in Multi‑Plaintiff Cases: Rush Truck Centers of Texas, L.P. & Blue Bird Body Co. v. Sayre