The Supreme Court of Texas has come through a period of rapid transition, and what some have called the court’s “conservative counterrevolution” certainly has not ended with the departure of its leader, Chief Justice Thomas R. Phillips, who retired from the Court in 2004. The court has set about establishing a consistent, moderately conservative approach that resists expansion of novel causes of action and theories of liability, while continuing to prune some of the precedents established during the previous era.