Justia Texas Court of Criminal Appeals Opinion Summaries

In 2021, a 14-year-old named Emanuel Ochoa was convicted of aggravated sexual assault of a child under 6, injury to a child causing serious mental injury, and kidnapping, all related to the sexual assault of a five-year-old girl. The key issue in this case was whether Ochoa's statements to law enforcement were made voluntarily. The court concluded that they were not.The trial court denied Ochoa's motion to suppress his statements, ruling that they were voluntary. The Second Court of Appeals upheld this decision, finding that Ochoa was not in custody during the pre-warnings portion of the interview and that his post-warnings statements were voluntary. The court noted that Ochoa and his mother went to the interview voluntarily, he was told he could leave at any time, and his freedom of movement was not restricted. The court also found that the statements made by the magistrate and the Texas Ranger did not render Ochoa's confession involuntary.The Court of Criminal Appeals of Texas reviewed the case and reversed the court of appeals' judgment. The court held that Ochoa's confession was involuntary under due process principles. The court emphasized that Ochoa's youth, lack of maturity, and inexperience with the legal system made him particularly vulnerable to coercive interrogation tactics. The court found that the combined effect of the Texas Ranger's misleading statements and the magistrate's incorrect information about Ochoa's rights overbore his will and rendered his confession involuntary. The case was remanded to the court of appeals for a harm analysis. View "OCHOA v. STATE OF TEXAS" on Justia Law

Randy Ethan Halprin, a member of the "Texas Seven," escaped from prison in December 2000 and was involved in the murder of Irving Police Officer Aubrey Hawkins during a robbery. Halprin was charged with capital murder and, in 2003, was convicted and sentenced to death by Judge Vickers Cunningham. Halprin's conviction and sentence were affirmed on direct appeal, and his initial habeas application was denied. Subsequent applications were dismissed. In 2019, Halprin filed a new writ application alleging that Judge Cunningham was biased against him because he is Jewish, violating his right to due process and the free exercise of his religion.The Texas Court of Criminal Appeals reviewed Halprin's claim after the trial court held an evidentiary hearing. The trial court found that Judge Cunningham exhibited actual bias against Halprin due to his Jewish faith and recommended granting Halprin a new trial. The State agreed that the evidence showed Cunningham's bias. The Texas Court of Criminal Appeals independently reviewed the record and confirmed that Cunningham's anti-Semitic remarks and behavior demonstrated actual bias.The Texas Court of Criminal Appeals concluded that Halprin had shown by a preponderance of the evidence that Judge Cunningham was biased against him at the time of the trial. This bias constituted a structural due process violation, entitling Halprin to a new trial. The court granted Halprin a new trial and dismissed his second claim challenging the constitutionality of the future dangerousness special issue as an abuse of the writ. View "In re Halprin" on Justia Law

The Texas Department of Public Safety detained and arrested the appellant for criminal trespassing as part of Operation Lone Star in Maverick County. Unlike the appellant, the two women in his group were transferred to the custody of the U.S. Border Patrol. The appellant claimed selective arrest and prosecution based on his sex and sought relief through pretrial habeas proceedings.The trial court held a hearing and heard testimony from various witnesses, including DPS officers and a client advocate. The court found that the appellant, along with other adult males, was arrested for criminal trespass while the women were transferred to federal custody due to jail capacity issues. The trial court denied the appellant's pretrial writ and motion to dismiss, concluding there was no sex discrimination.The Fourth Court of Appeals, sitting en banc, held that the appellant's claim was cognizable on pretrial habeas and found that he had demonstrated a prima facie case of sex discrimination. The appellate court reversed the trial court's ruling and remanded the case to allow the State to rebut the presumption of sex discrimination under strict scrutiny.The Court of Criminal Appeals of Texas reviewed the case and agreed that the appellant's claim was cognizable. However, the court found that the appellant failed to meet the demanding burden of showing a prima facie case of selective enforcement or prosecution. The court noted that the evidence suggested the discriminatory effect was due to logistical issues during an ongoing state of emergency, rather than intentional sex discrimination. The court reversed the appellate court's decision and affirmed the trial court's denial of relief. View "EX PARTE APARICIO" on Justia Law

In 2009, the applicant was convicted of possessing more than one but less than four grams of cocaine and sentenced to two years and nine months in prison following a guilty plea. The conviction involved former Houston Police Department Officer Gerald Goines, who has been found to have provided false information and testimony in other drug cases. In 2019, the Harris County District Attorney’s Office informed the applicant that Goines was under criminal investigation. The applicant then filed for a writ of habeas corpus, initially on four grounds, but later amended it to focus solely on the claim that his guilty plea was involuntary due to not knowing about Goines’s misconduct.The 184th District Court of Harris County recommended granting relief, finding that the applicant’s guilty plea was involuntary and that the conviction was obtained through the use of false evidence. The court concluded that the applicant had established an inference of falsity under the Coty-Mathews framework, which applies to cases involving police officers with a history of falsifying evidence. The court found that the false evidence was material to the applicant’s guilty plea.The Court of Criminal Appeals of Texas reviewed the case to determine whether Goines’s conduct warranted an inference of falsity. The court concluded that the record did not support the habeas court’s conclusion because Goines was not the sole officer involved in the applicant’s arrest, and the evidence did not establish that Goines was the first to find the contraband. Therefore, the court held that an inference of falsity did not apply and remanded the case to the habeas court to consider the applicant’s involuntary plea claim without applying an inference of falsity. View "EX PARTE CHRISTIAN" on Justia Law

The case revolves around a defendant who was convicted of continuous sexual abuse of a child and sentenced to sixty years in prison. The defendant was the victim's mother's boyfriend, and they lived together for about five years. The victim testified that the defendant sexually abused her when she was six or seven years old. The abuse was reported to the Polk County Sheriff’s Department by Alyssa Crawford, who learned about it from the victim. Two years later, during the trial, the State moved to present Crawford’s testimony via Zoom due to her fear of retaliation, her responsibility of caring for her husband with a broken back, and a conflicting court appearance in Colorado. The defendant objected, arguing that allowing Crawford to testify remotely would violate his right to confront her face to face.The trial court overruled the defendant's objection and allowed Crawford to testify via Zoom. The court of appeals, however, reversed the conviction, holding that the trial court’s necessity finding in support of its ruling was too general and unjustified by any public-policy interest.The Court of Criminal Appeals of Texas disagreed with the court of appeals. It held that the trial court’s necessity finding was sufficient and justified by the witness’s fear of retaliation. The court noted that retaliation is a crime and protecting witnesses from retaliation is an important public-policy interest. The court also pointed out that Crawford had provided a basis for her fear—death threats and break-ins at her home soon after her report to the sheriff. Therefore, the court reversed the judgment of the court of appeals and remanded the case for further proceedings. View "MCCUMBER v. STATE OF TEXAS" on Justia Law