Justia Texas Court of Criminal Appeals Opinion Summaries

In this case, Hector Acosta was convicted of capital murder for fatally shooting Erick Zelaya and Iris Chirinos in the same criminal transaction. The trial court sentenced Acosta to death based on the jury’s answers to special issues set forth in Texas Code of Criminal Procedure Article 37.071, Sections 2(b) and 2(e). Acosta appealed, raising seventeen points of error.The Court of Criminal Appeals of Texas affirmed the trial court’s judgment of conviction and sentence of death. The court found that the trial court did not err in denying Acosta's motions for continuance, motions to suppress, and in admitting certain evidence. The court also found that Acosta's statements to the police were voluntary and that he had knowingly and intelligently waived his Miranda rights. The court further found that the trial court did not abuse its discretion in admitting surveillance video footage, as it was properly authenticated.The court also rejected Acosta's arguments that the State improperly highlighted his Mexican nationality as evidence of future dangerousness, finding that the State did not offer specific evidence of Acosta’s Mexican nationality as evidence of future dangerousness, nor did the State argue that Acosta was a future danger because he is Mexican or from Mexico. The court concluded that Acosta failed to preserve these claims at trial, and therefore, the court could not review them on appeal. View "Acosta v. State" on Justia Law

The case revolves around an incident where the appellant, after spending time at a bar called the Crying Shame, retrieved his registered handgun from his motorcycle's saddlebag and placed it in his waistband. As he was about to leave, he was approached by three bar patrons, leading to a physical altercation in the parking lot. During the altercation, the gun was removed from the appellant's pants and thrown onto the bar's roof. The appellant was charged with unlawful carrying of a weapon, which was enhanced to a third-degree felony by alleging the offense occurred on a “premises” licensed to sell alcoholic beverages.The trial court used the definition of “premises” from the Alcoholic Beverage Code in its charge to the jury, which included the grounds and all buildings, vehicles, and appurtenances pertaining to the grounds, including any adjacent premises if they are directly or indirectly under the control of the same person. The jury found the appellant guilty and he was sentenced to four years in the Texas Department of Criminal Justice, which was probated for four years.On appeal, the appellant argued that the State did not prove beyond a reasonable doubt that the parking lot was part of the “premises” of the Crying Shame. The court of appeals initially affirmed the trial court’s judgment but later reversed the conviction on remand from the Court of Criminal Appeals of Texas, holding that the State’s evidence was legally insufficient to support the statutory enhancement beyond a reasonable doubt.The Court of Criminal Appeals of Texas affirmed the court of appeals' decision, stating that the State did not provide legally sufficient evidence to support an enhancement element beyond a reasonable doubt. The case was remanded to the trial court for a new punishment hearing. View "BALTIMORE v. STATE OF TEXAS" on Justia Law

The case involves Darren Tramell Hughes, who was on deferred adjudication community supervision. The State filed a motion to adjudicate guilt, alleging that Hughes had violated the terms of his supervision by committing two forgery offenses and failing to pay required fees. The hearing on the motion was conducted via Zoom due to COVID-19 restrictions. During the hearing, Hughes was muted several times when he attempted to speak. Hughes was subsequently found guilty and sentenced to ten years imprisonment.On appeal, Hughes argued that his right to be present under the Due Process Clause was violated due to his muting during the hearing. The court of appeals reversed the decision, holding that his right to be present under the Confrontation Clause was violated, even though Hughes did not raise this issue in his brief. The court of appeals found that Hughes was turned into a passive observer, unable to communicate with his counsel and participate in his own defense.The case was then brought before the Court of Criminal Appeals of Texas. The court agreed with the lower court's decision that Hughes's right to be present was violated. However, it clarified that the right to be present under the Due Process Clause, not the Confrontation Clause, applies in hearings on motions to adjudicate guilt. The court further explained that this right is waivable, not forfeitable, and that Hughes did not waive this right. The court concluded that the trial court's action of muting Hughes was not harmless and affected his ability to defend himself. The judgment of the court of appeals was affirmed, and the case was remanded to the trial court for further proceedings. View "HUGHES V. STATE OF TEXAS" on Justia Law

In 1987, six young women and girls disappeared in El Paso, Texas, and were later found buried in shallow graves. In 1992, David Leonard Wood was convicted of capital murder and sentenced to death for these crimes. Since then, Wood has filed multiple motions for DNA testing, the first of which was granted in 2010. However, subsequent motions resulted in proceedings that stretched over a decade, with the trial court ultimately denying DNA testing in 2022.In the lower courts, Wood's conviction and sentence were affirmed on direct appeal in 1995. He filed a state habeas application in 1997, which was denied in 2001. Over the years, Wood filed multiple motions for DNA testing, the first of which was granted in 2010. However, the remaining DNA motions resulted in proceedings that stretched over a decade, with the trial court ultimately denying DNA testing in 2022.In the Court of Criminal Appeals of Texas, Wood appealed the 2022 denial of testing. He raised six issues, only two of which directly addressed the question of whether he should have been granted DNA testing of biological evidence. The court concluded that none of Wood’s issues had merit and affirmed the trial court’s order. The court held that Wood failed to meet the second prong of Article 64.03(a)(2): he failed to show that his subsequent DNA testing requests were not made to unreasonably delay the execution of his sentence. View "WOOD V. STATE OF TEXAS" on Justia Law

The case revolves around the defendant, Larry Jean Hart, who was charged with capital murder while committing or attempting to commit the felony offense of burglary. Hart drove an acquaintance and three other individuals to an apartment complex where they robbed and shot the complainant, Michael Gardner. Hart claimed he remained in the car during the incident and was unaware of the group's intentions. The State argued that Hart knew about the planned crime and should have anticipated the outcome.The trial court admitted rap videos during the guilt phase of the trial to demonstrate Hart's character and sophistication. Hart objected, arguing that the videos' prejudicial effect outweighed their probative value. The trial court overruled Hart's objections, stating that Hart's testimony opened the door to character witness evidence. The jury found Hart guilty and sentenced him to life without parole.On appeal, Hart argued that the trial court erred in admitting the rap videos, among other things. The appellate court upheld the trial court's ruling, stating that the rap videos were relevant to Hart's ability to comprehend and form intent regarding the planned crime. The court also conducted a balancing test under Rule 403 and concluded that the trial court's ruling did not constitute a clear abuse of discretion.The Court of Criminal Appeals of Texas disagreed with the lower courts. It found that the rap videos' probative value was outweighed by their potential for prejudice and confusion. The court reversed the judgment of the appellate court and remanded the case to the trial court for further proceedings. View "Hart v. State of Texas" on Justia Law

The case revolves around a woman who was convicted of theft in 2015. The prosecution used her 2001 federal felony conviction from Alaska to enhance the theft offense to a first-degree felony, resulting in a forty-year sentence and a $10,000 fine. The woman argued that her 2001 federal conviction was not final when the theft occurred, and thus, the offense was unlawfully enhanced, leading to an illegal sentence.Prior to reaching the Court of Criminal Appeals of Texas, the case had been reviewed by lower courts. The main issue was whether Texas law or the law of another jurisdiction should be used to determine if a prior conviction is final for the purpose of enhancing the punishment of an offense under Section 12.42 of the Texas Penal Code.The Court of Criminal Appeals of Texas was asked to determine whether there was ever a time prior to a previous case, Ex parte Pue, when other states were allowed to unilaterally dictate the laws and public policy of Texas. The court held that the rule in Pue, which stated that Texas law should define whether a prior conviction is final for the purposes of enhancing the punishment of an offense, applies retroactively. Furthermore, the court held that the woman's federal felony conviction was final under the rule in Pue. The court concluded that the woman's federal conviction was final under Texas law and denied her relief. View "EX PARTE MCMILLAN" on Justia Law

The appellant, sentenced to death for capital murder, had his conviction and sentence affirmed by the Court of Criminal Appeals of Texas. He submitted multiple motions and applications challenging his competence to be executed, all of which were denied by the trial court and affirmed by the appellate court.In 2015, the appellant made a motion challenging his competence to be executed. The trial court denied the motion, but on appeal, the Court of Criminal Appeals of Texas ruled that the appellant made a substantial showing of incompetence and stayed his execution. The case was remanded for further competency proceedings, including a mental health evaluation. After a hearing in 2017, the trial court again ruled that the appellant was competent for execution, a decision affirmed by the appellate court.In September 2019, the appellant filed another motion challenging his competency. The trial court denied the motion and the appellant appealed. In April 2020, he filed a subsequent application for a writ of habeas corpus, alleging intellectual disability and ineligibility for the death penalty under Atkins v. Virginia.The Court of Criminal Appeals of Texas stayed the execution and remanded the application to the trial court for review. In February 2023, the trial court recommended relief on the intellectual disability claim. Based on the agreed findings and conclusions, the appellate court granted habeas relief by reforming the appellant's sentence from death to life imprisonment without parole.Therefore, the appellant's appeal of the trial court's determination of his competency to be executed was rendered moot, and the appeal was dismissed. The holding of the case is that the appellant's sentence was reformed from death to life imprisonment without parole due to his intellectual disability claim. View "Mays v. State" on Justia Law

The Court of Criminal Appeals of Texas ruled that a peace officer can legally arrest a suspect, without a warrant, for killing another person while driving intoxicated, even if the accident did not occur in the officer's presence. This interpretation is based on the Texas Code of Criminal Procedure 14.03(a)(1), which allows any peace officer to arrest a person found in a “suspicious place” and the circumstances reasonably show that the person is guilty of a felony or breach of peace.The case involved Sean Michael McGuire, who was arrested on suspicion of causing another person's death by driving while intoxicated and failing to stop and render aid. Prior to his arrest, McGuire hit a motorcycle, causing the death of its driver, then drove to a nearby gas station where he was later found by the police. The police officer noted that McGuire exhibited signs of intoxication and had "red glassy eyes" and "an odor of alcohol coming from his person." As a result, the officer formed probable cause to believe that both a felony and breach of the peace had occurred.The court found that McGuire's arrest met the requirements of the Texas Code of Criminal Procedure 14.03(a)(1) and thus reversed the court of appeals and the trial court’s suppression of McGuire’s arrest and all evidence arising from it. The case was remanded back to the trial court for further proceedings. View "State v. McGuire" on Justia Law

In Texas, the appellant was stopped by an officer for failing to remain in a single lane of traffic. After the officer smelled alcohol on the appellant's breath and observed signs of intoxication, he obtained a warrant for a blood sample, which showed a blood alcohol content of .174. The appellant was subsequently indicted for felony driving while intoxicated. The appellant filed a pre-trial motion to suppress, arguing that the officer did not have reasonable suspicion for the traffic stop. The trial court denied the motion, and the appellant was convicted. The appellant appealed, and the Third Court of Appeals reversed the conviction, holding that the stop was unlawful because the appellant's failure to maintain a single lane was not unsafe.The Court of Criminal Appeals of Texas considered whether a mistake of law should apply when an officer conducts a search or seizure under an ambiguous law. The court held that the officer's reasonable misinterpretation of the law did not undermine the reasonable suspicion required to conduct the traffic stop. The court noted that at the time of the stop, there was no controlling interpretation of the relevant section of the Texas transportation code from the Court of Criminal Appeals and the intermediate courts were split in their interpretations. The court therefore reversed the court of appeals' decision and affirmed the trial court's judgment. View "Daniel v. State" on Justia Law

In a case reviewed by the Court of Criminal Appeals of Texas, the trial court mistakenly permitted an alternate juror to participate in the jury's deliberations and vote on the defendant's guilt. The defendant, charged with unlawful possession of a firearm by a felon, argued that this violated constitutional and statutory provisions requiring a jury to consist of twelve people and prohibiting any person from being with the jury while it was deliberating. On review, the Court of Criminal Appeals held that the presence and participation of an alternate juror during jury deliberations did not violate the constitutional or statutory requirements regarding the size of a jury. However, the Court held that the alternate juror’s presence and participation during deliberations did violate the statutory prohibitions against a “person” being with the jury while it is deliberating and conversing with the jury about the case. As such, the Court remanded the case to the lower court to conduct a harm analysis, i.e., to determine whether the alternate juror's presence and participation during deliberations had a substantial or injurious effect on the jury's verdict. View "BECERRA v. STATE" on Justia Law