Rule 91.Special Exceptions
Last verified June 28, 2026
Full Text of Rule 91
Plain-English Summary
Rule 91 sets the form of a special exception — the tool for attacking a defective pleading. It is not enough to say a pleading is inadequate; the exception must point out the particular pleading and then identify, intelligibly and with particularity, the defect, omission, obscurity, duplicity, generality, or other insufficiency in the allegations.
Frequently Asked Questions
What is a special exception in Texas?
Under Rule 91, a written objection that points out, with particularity, a specific defect in an opponent's pleading — such as vagueness, duplicity, or omission.
Is it enough to tell the court a pleading is unclear in Texas?
No. Rule 91 requires the exception to point out the pleading at issue and then identify, with particularity, the defect, omission, obscurity, duplicity, generality, or other insufficiency in it.
What kinds of pleading problems can a special exception target in Texas?
Rule 91 lists defect, omission, obscurity, duplicity, and generality, along with a catch-all for other insufficiency in the allegations.