concurring.
The majority states that “if an application for habeas relief under federal law challenges an inmate’s confinement, then the court of criminal appeals’s character*409ization of the proceedings as criminal still applies.”1 I agree, but I write separately because the majority does not but should expressly hold that Walp’s habeas action in this case was a challenge to his confinement.
Under Texas law, with limited exception, the State must release an inmate to mandatory supervision when his time served plus good conduct time equals his sentence.2 The court of criminal appeals has granted habeas relief under article 11.07 when an inmate who was entitled to immediate release under mandatory supervision was still confined despite his right to release.3
But the court of criminal appeals apparently sees a difference between (1) a claim by an inmate entitled to immediate mandatory release that he is being illegally detained in violation of the mandatory supervision provision, and (2) an inmate’s challenge to a disciplinary proceeding that resulted in the loss of good-time credit, which would then result in the inmate at some point in the future being detained beyond the point at which he would have been entitled to mandatory supervision had good-time credit not been forfeited. That court has indicated that a challenge to the loss of good-time credit is a challenge to the condition, rather than the fact, of the inmate’s confinement.4
The United States Supreme Court, on the other hand, has held that an inmate who challenges a disciplinary proceeding that resulted in the loss of good-time credit, even when the inmate is seeking only speedier (rather than immediate) release, is “attacking the very duration of [his] physical confinement itself.”5 Thus, the U.S. Supreme Court would characterize Walp’s habeas action as challenging his confinement. I agree with the characterization of the U.S. Supreme Court.
Furthermore, although the court of criminal appeals would not grant habeas relief in such cases, I agree with the majority’s implicit holding that, for purposes of classifying such an action as civil or criminal, that court would also consider such an action as complaining about the inmate’s confinement. Although an inmate in such a situation would be challenging future rather than current confinement, such a complaint cannot logically be classified as merely challenging prison conditions. This is so even if the inmate challenges the loss of good-time credit by way of attacking the prison’s disciplinary proceedings that resulted in the credit loss. In this case, Walp appears to have challenged his continued confinement, and, therefore, he challenged the fact of his confinement.
If the majority does not wish to go so far as to hold that a challenge to prospective confinement is a criminal proceeding *410under Texas law, it could still expressly hold that a challenge to the loss of good-time credit that would entitle the inmate to immediate release is a criminal proceeding. And because it was not clear from the evidence that Walp did not seek immediate release, Williams did not meet his burden to show that Walp’s habeas action was a civil proceeding. But either way, this court should expressly state that Walp’s complaint about prison disciplinary procedures and the loss of good-time credit was a challenge to his confinement.
I also write to address Walp’s second issue, in which he asserts that the trial court erred by excluding his evidence. At the hearing on Williams’s motion, Walp opened his argument by stating, “I would like to begin with introducing Exhibit A,” his answers to Williams’s interrogatories. He then described ten other exhibits he had brought with him, all relating to whether his claims had merit. Walp did not offer the documents to Williams for inspection or ask the court reporter to mark them as exhibits. Near the end of the hearing, the following exchange occurred:
THE COURT: Anything further?
[Attorney for Williams]: No, Your Honor.
THE COURT: Okay.
[Walp]: What about my exhibits?
THE REPORTER: They were never admitted.
[Walp]: Well, I need to admit them.
THE COURT: Well, they weren’t ... offered.
[Walp]: So you’re going to get me on a technical? I didn’t know how to offer the evidence. I said I had some exhibits.
THE COURT: You didn’t make the offer to allow your opponent the opportunity to either object or not object to them.
[Walp]: Well, I have no knowledge of — of those — I don’t have no knowledge of — of the formality of doing that. I sat here and said I had some exhibits that I needed to enter and I read them off. Now you’re going to deny my exhibits on a technicality?
THE COURT: No, they were not offered.
On remand, if Williams files another motion to declare Walp a vexatious litigant, the trial court will be required to conduct a hearing before ruling on the motion.6 If Walp is present at that hearing,7 he will almost certainly attempt, once again, to offer evidence to rebut Williams’s arguments that there is no reasonable probability that he would prevail on his claims. Walp’s ignorance of the usual procedures that attorneys use for offering evidence will likely result in frustration from all sides, and, if the outcome of the hearing is unfavorable to him, an appeal raising this same issue. Judicial economy therefore suggests that we should address this sure-to-be-raised-again issue now rather than spend further judicial resources addressing it later. Furthermore, Walp’s ignorance of evidentiary procedure will divert the trial court’s and the parties’ attentions away from where it belongs — on the merits — and focus it on arguments about what magic words a party must use to have the *411trial court consider the admissibility of evidence. In the interest of judicial economy, and to eliminate one unnecessary ground for contention on remand, I note that generally, a party wishing to place a document into evidence should produce the document and in some way signify that he is offering it into evidence, allow the opposing party to inspect the evidence and make any objections to its admission, have the evidence marked as an exhibit by the court reporter, and hand it to the trial judge.8 Though helpful, there is no need for a party wishing to place a document into evidence to specifically use the word “offer.”9
Because I agree with the majority’s holding, I respectfully concur.
. Majority op. at 407.
. Tex. Gov’t Code Ann. § 508.147 (Vernon 2004) (''[A] parole panel shall order the release of an inmate who is not on parole to mandatory supervision when the actual calendar time the inmate has served plus any accrued good conduct time equals the term to which the inmate was sentenced.”), § 508.149 (Vernon 2004) (setting out circumstances in which an inmate is not eligible for mandatory supervision).
. See, e.g., Ex parte McGee, 962 S.W.2d 49, 49 (Tex.Crim.App.1998).
. See Ex parte Palomo, 759 S.W.2d 671, 674 (Tex.Crim.App.1988) (noting that the court of criminal appeals does not consider complaints about disciplinary proceedings or the loss of good-time credit, which relate to the terms and conditions of an inmate’s imprisonment, by way of a writ of habeas corpus).
. Preiser v. Rodriguez, 411 U.S. 475, 487-88, 93 S.Ct. 1827, 1835, 36 L.Ed.2d 439 (1973).
. See Tex. Civ. Prac. & Rem.Code Ann. § 11.053 (Vernon 2002) (requiring a hearing before ruling on a motion to declare a party a vexatious litigant).
. See Garrett v. Macha, No. 02-09-443-CV, 2010 WL 3432826, at *3 (Tex.App.-Fort Worth Aug. 31, 2010, no pet.) (mem. op.) (noting that an inmate does not have an absolute right to be present at a hearing on a motion to declare him a vexatious litigant).
. See Guetersloh v. C.I.T. Corp., 451 S.W.2d 759, 760 (Tex.Civ.App.-Amarillo 1970, writ ref'd n.r.e.).
. Id.