Justia Texas Court of Criminal Appeals Opinion Summaries

Appellant Christopher Miranda, a high school gymnastics coach in El Paso, was accused of having improper relationships with three of his female students. He confessed to a school administrator to engaging in sexual intercourse with each student. This case involved one of those students and whether the corpus delicti of the offenses perpetrated against her was shown by independent corroborating evidence. The court of appeals concluded that they had not, finding instead no evidence corroborating Appellant’s confession and that the closely-related-crimes exception to strict application of the corpus delicti rule did not apply. It rendered acquittals on some counts. After review, the Texas Court of Criminal Appeals disagreed with the appellate court and reinstated Appellant's convictions. View "Miranda v. Texas" on Justia Law

Early one morning in March 2017, a telephone caller to the Van Alstyne Police Department reported a gray minivan being driven erratically. The caller, who was driving in the same direction, followed the minivan to a gas station, told police where it had been parked, relayed the vehicle’s license plate information, then hung up. The caller did not describe the driver. Police found the minivan a few minutes later. The motor was off, and Appellant Robert Harrell, Jr. was in the driver’s seat with the seatbelt buckled. There was no evidence about where the keys were, but Appellant admitted he had been driving. There were two passengers in the back. All three people in the minivan were intoxicated. The court of appeals held that the evidence did not tend to show the corpus delicti of DWI because, absent Appellant’s extrajudicial confession, there was insufficient evidence that he operated the minivan. The Texas Court of Criminal Appeals concluded the evidence was sufficient to support Appellant’s conviction, reversed the court of appeals' judgment, and remanded the case for the lower court to address Appellant’s remaining issue. View "Harrell v. Texas" on Justia Law

Appellant Matthew Allen was convicted by jury of committing Continuous Sexual Abuse of a Young Child, Indecency with a Child by Exposure, and Indecency with a Child by Contact. Appellant challenged the sufficiency of the evidence, and the court of appeals upheld the convictions for Continuous Sexual Abuse of a Young Child and Indecency with a Child by Contact, but reversed the Indecency with a Child by Exposure conviction. In upholding the Indecency with a Child by Contact conviction, the court of appeals modified the judgment to state that the offense was committed in December 2011, which was within the October 1, 2009–August 15, 2012 time period that the indictment alleged for the Continuous Sexual Abuse of a Young Child offense. The Texas Court of Criminal Appeals held that Appellant’s conviction for Indecency with a Child by Contact violated Penal Code section 21.02(e)(2). The Court found the evidence supporting the Indecency with a Child by Contact offense showed that it occurred within the time period the Continuous Sexual Abuse of a Young Child offense was committed. The Court affirmed the judgment of the court of appeals in part, reversed the judgment of the court of appeals in part, and vacated Appellant’s conviction for Indecency with a Child by Contact. View "Allen v. Texas" on Justia Law

In March 2005, a jury found Applicant Humberto Garza guilty of murdering six men in the course of committing or attempting to commit robbery. Applicant was sentenced to death for these crimes, and his sentence was affirmed on direct appeal. Applicant filed his initial habeas corpus application in 2007 raising twenty-eight claims for relief, including twelve allegations of ineffective assistance of counsel. Over five years after Applicant filed his initial application, and after prompting by the Texas Court of Criminal Appeals, the trial court entered an order designating issues. In that order, the trial judge directed lead trial counsel and co-counsel to file affidavits responding to Applicant’s ineffective-assistance-of-counsel allegations. The trial court held an evidentiary hearing in August 2014, during which both attorneys testified. In February 2015, the trial court signed a 635-page order adopting findings of fact and conclusions of law recommending that Applicant be denied relief on all grounds. In his third allegation, Applicant asserted that his trial counsel’s failure to conduct a constitutionally adequate investigation of mitigating evidence deprived him of his Sixth Amendment right to effective assistance of counsel pursuant to Wiggins v. Smith, 539 U.S. 510 (2003). The Court of Criminal Appeals remanded this claim to the trial court for further development. The trial court signed an order adopting supplemental findings of fact and conclusions of law, recommended denying relief, and returned the case the Court of Criminal Appeals. After remand, the Court filed and set the case and directed the parties to submit briefs on Applicant’s third allegation. Based on its independent review of the record, the Court concluded Applicant was entitled to a new punishment hearing because his trial counsel’s mitigation investigation fell below an objective standard of reasonableness, and had counsel not been deficient, there was a reasonable probability that at least one juror would have struck a different balance and would have answered the mitigation issue differently, voting to spare Applicant’s life. View "Ex parte Humberto Garza" on Justia Law

After the trial court denied his motion to suppress his confession, Appellant Jesse Martinez pled guilty to murder and was sentenced to 30 years in prison. Appellant was 19 years old, had no prior arrests, and had never before been questioned by the police. In April 2016, police officers arrived at his mother's house after midnight without a warrant for the purpose of questioning him about the disappearance of his friend, Tristan Mina. They took him to the police station in an unmarked car. His mother followed in her own car and waited in the family area when they took him to an interrogation room. She told him that she would get him an attorney. Appellant waited in the interrogation room alone for several minutes before two detectives, Michael Lara and Rex Parsons, joined him there. Detective Lara read Appellant his Miranda rights. Appellant invoked his right to counsel, and the interview was terminated. The detectives told Appellant that he was under arrest for murder and locked him in a holding cell where he was handcuffed to a bench. Less than fifteen minutes later Appellant "flagged down" Lara and said he would give a statement. Appellant was returned to the interrogation room and was again read his Miranda rights. He said he understood the rights and wished to continue. He then gave an hour-long videotaped statement recounting the events of the night that Mina was killed. On appeal he challenged the suppression ruling, claiming that his confession was the product of an illegal arrest. The court of appeals held that the taint was sufficiently attenuated under Brown v. Illinois, 422 U.S. 590 (1975), and affirmed the trial court. The Texas Court of Criminal Appeals granted review of this matter to determine whether the court of appeals misapplied the four-factor test from Brown and whether the court of appeals' finding of probable cause was based on opinions rather than facts in conflict with Torres v. Texas, 182 S.W.3d 899 (Tex. Crim. App. 2005). The Court concluded the court of appeals misapplied the third and fourth Brown factors and erred in looking to Appellant's statement to establish probable cause for his arrest. Judgment was therefore reversed and the case remanded to the trial court for further proceedings. View "Martinez v. Texas" on Justia Law

Appellant Dallas Curlee was convicted of possession of a controlled substance within 1,000 feet of a drug-free zone (a playground). Appellant challenged the sufficiency of the evidence, specifically, the requirement that the playground was “open to the public.” The evidence pertinent to the “open to the public” element consisted of the fact that the playground was surrounded by a chain link fence that was not completely locked, an officer’s conclusory testimony that the playground was open to the public, the playground’s location on the premises of a church, and the fact that the playground could be seen through the fence. The Texas Court of Criminal Appeals concluded that a rational jury could not conclude, beyond a reasonable doubt, that the playground was “open to the public” based on the evidence presented at trial. Therefore, the Court ruled the evidence was insufficient to support the “open to the public” element of a playground, and reversed the judgment of the court of appeals. View "Curlee v. Texas" on Justia Law

The issue this case presented for the Texas Court of Criminal Appeals was at what point could an appellant timely object to the thirteenth juror's presence when an alternate juror retires with the jury and was present during deliberations: when the jury retires to deliberate, or when an appellant becomes aware that the alternate was present during deliberations. The Court concluded that the grounds for Appellant’s objection to the alternate juror being sent into the jury room were not apparent until counsel became aware of the error. Because Appellant’s objection, motion for mistrial, and motion for new trial were timely, and the court of appeals erred by failing to reach the merits of Appellant’s statutory and constitutional claims. View "Becerra v. Texas" on Justia Law

The issue this case presented for the Texas Court of Criminal Appeals centered on whether a police officer's entry into a residence was reasonable under the Forth Amendment, when a firefighter, in the line of duty, asked law enforcement for a safety check after seeing drug paraphernalia, guns, and flammable liquids in the residence, and whether that officer’s discovery of drug paraphernalia in plain view provided probable cause for a search warrant? The short answer to this question under the specific facts of this case was yes: the Court therefore upheld the court of appeals’ judgment which affirmed the trial court’s denial of Appellant’s motion to suppress the drug evidence found pursuant to a search warrant. View "Martin v. Texas" on Justia Law

In November 2017, a jury convicted Appellant William Hudson of capital murder for murdering Carl and Hannah Johnson. Pursuant to the jury’s answers to the special issues set forth in Texas Code of Criminal Procedure Article 37.071, sections 2(b) and 2(e), the trial judge sentenced Appellant to death. On automatic appeal, Appellant raised two points of error. After reviewing Appellant’s points of error, the Texas Court of Criminal Appeals found them to be without merit. Consequently, it affirmed the trial court’s judgment and sentence of death. View "Hudson v. Texas" on Justia Law

Applicant Steven Thomas was 16 when he committed capital murder. When he was 19, the juvenile court waived its exclusive jurisdiction and transferred Applicant’s case to district court, where Applicant pleaded guilty to a lesser charge of murder. Decades passed. Applicant did not appeal his transfer or his case or file a writ of habeas corpus. Then, the Texas Court of Criminal Appeals decided Moon v. Texas, 451 S.W.3d 28 (Tex. Crim. App. 2014), which held that if an order waiving juvenile jurisdiction did not contain factually-supported, case-specific findings, then the order is invalid, and the district court never acquires jurisdiction. Based upon Moon, Applicant argued that because the order waiving juvenile jurisdiction did not contain factually-supported, case-specific findings, it was invalid, and thus the district court never acquired jurisdiction. The Court of Criminal Appeals found that the type of findings Moon required were neither grounded in the text of the transfer statute, nor in Kent v. United States, 383 U.S. 541 (1966), the Supreme Court precedent that it purportedly relied upon in Moon. "Requiring them may be good policy, but the lack of case-specific findings has nothing to do with jurisdiction, fundamental constitutional rights, or even the transfer statute itself. The juvenile court’s transfer order in this case may have lacked factually-supported, case-specific findings, but that did not make that order invalid or deprive the district court of jurisdiction." Consequently, the Court determined Applicant was not entitled to habeas corpus relief. View "Ex parte Steven Thomas" on Justia Law