Justia Texas Court of Criminal Appeals Opinion Summaries

The state sought reversal of the judgment of the court of appeals, which held that a blood-draw search warrant to be executed in a designated county could not be issued by a statutory county court judge of another county. The court held that the court of of appeals did not err in determining that a statutory county court judge in Montgomery County lacked authority to issue a search warrant for defendant's blood in Harris County. Statutory county court judges lacked the authority to issue a search warrant to be executed outside of their own county and therefore, the judgment was affirmed. View "Sanchez v. State" on Justia Law

A jury convicted defendant of capital murder and sentenced him to life in prison with no possibility of parole. On appeal, defendant claimed he was denied due process at his trial. At issue was whether defendant's objections at trial put the court on notice of his due-process, fair-trial complaint. The court held that the court of appeals used the correct standard and did not err in failing to consider the court's holding in Zillender v. State. Contrary to defendant's argument, the court's holding in Zillender did not change the outcome of his appeal where nothing in the record indicated that the trial court or prosecutor knew that defendant was making a due-process claim. Therefore, defendant never put the court on notice of his due-process, fair-trial complaint, and the issue was forfeited. Accordingly, the court affirmed the judgment. View "Clark, III v. State" on Justia Law

Defendant was arrested for driving while intoxicated and the trial judge subsequently granted her motion to suppress, concluding that the officer lacked reasonable suspicion to make his traffic stop. The state appealed that ruling and requested written findings of fact and conclusions of law. Based upon the trial judge's written factual findings, the court of appeals inferred that the judge must have believed the officer's testimony. The court granted defendant's petition to review whether the court of appeals deferred sufficiently to the trial court's factual findings. The court agreed with defendant that reviewing courts should not make implied findings of fact and credibility determinations that were contrary to the trial judge's ultimate ruling. But because the written findings in this case were ambiguous and there was no credibility determination, the court remanded the case to the court of appeals with instructions to abate the case to the trial judge for supplemental findings. View "State v. Mendoza" on Justia Law

Defendant was arrested for driving while intoxicated. Prior to his trial, defendant moved to suppress all evidence obtained as a result of the traffic stop on the basis that the officer's traffic stop was improper because he did not have reasonable suspicion that defendant had committed a criminal offense. At the suppression hearing, the officer testified that he saw the car that was driving in front of defendant slow down at the railroad tracks and he saw defendant pass the slowing car on the shoulder. The officer said that he initiated the traffic stop based solely on that behavior. The court held that the officer did not have reasonable suspicion that defendant was illegally driving on an improved shoulder. Accordingly, the court reversed and remanded. View "Lothrop v. State" on Justia Law

Defendant appealed the trial court's denial of his Batson motion, which he filed after all of the black venire members in the strike zone were struck by the State. The First Court of Appeals held that the trial court clearly erred in failing to find that the State's proffered race-neutral reasons were a pretext for racial discrimination. The court held that the record did not demonstrate that the trial court clearly erred by finding that the reasons proffered by the State were facially sufficient to show race-neutral reasons for the strike. Therefore, the court reversed and remanded. View "Nieto v. State" on Justia Law

Defendant was charged with driving while intoxicated (DWI). In this second petition for discretionary review filed by defendant, the court determined that the court of appeals erred by holding that a driver must signal a lane change when his lane merged with another lane. The court held that the arresting officer failed to articulate specific facts that supported a reasonable suspicion that defendant had violated Tex. Transp. Code 545.104(a). Therefore, the court held that there was no reasonable suspicion for the initial stop and that the trial court erred by failing to suppress the evidence obtained as a result of the stop. Accordingly, the court reversed the judgment and remanded. View "Mahaffey v. State" on Justia Law

Defendant was charged with indecent exposure, enhanced with a prior conviction for the same offense. A conflict existed between the trial court's oral denial of a motion to quash defendant's information and its subsequent written order granting the same motion. The state asked the court to reverse the judgment of the court of appeals, which held that the trial court lost jurisdiction to accept defendant's guilty plea after it signed the order granting his motion to quash. The court granted the State's petition for discretionary review and vacated the judgment because the plain language of Texas Rule of Appellate Procedure 44.4 required the court of appeals to abate the case. View "Henery v. State" on Justia Law

Defendant was convicted of ten counts of possession of child pornography. The ten counts were for ten images of unknown children discovered in the "free space" of defendant's computer. In this petition for discretionary review, the State contended that the court of appeals erred in finding the evidence insufficient to support convictions against defendant. The court concluded that the majority misapplied the standard of review for sufficiency by focusing on the possible alternative explanations, rather than determining whether the jury's inference was reasonable based upon the cumulative force of all the evidence when considered in the light most favorable to the verdict. Therefore, the court reversed the judgment of the court of appeals and rendered a judgment affirming the trial court. View "West v. State" on Justia Law

Defendant was convicted of murder and the court granted defendant's petition for discretionary review on one ground: whether the Court of Appeals erred in holding that the Fifth Amendment right against compelled incrimination did not apply to pre-arrest, pre-Miranda silence used as substantive evidence of guilt in cases in which a defendant did not testify. The court held that such silence was admissible and affirmed the judgment, upholding the conviction. View "Salinas v. State" on Justia Law

Applicant was convicted of felony murder and injury to a child where the child chocked on a wad of paper towels while applicant was babysitting him. Applicant subsequently filed an application for a writ of habeas corpus and the habeas judge recommended that the court grant applicant a new trial. Although the court agreed with some of the habeas judge's factual findings, the court did not adopt them all because some of them were not supported by the trial and habeas records. As the ultimate factfinder, the court reviewed all of the evidence and found that applicant has failed to show that she was entitled to a new trial and therefore, the court denied relief. View "Ex Parte Jimenez" on Justia Law