Justia Texas Court of Criminal Appeals Opinion Summaries

A jury convicted appellant of felony possession with intent to deliver cocaine in an amount over 400 grams. The trial court sentenced him to thirty years' confinement in the penitentiary. Appellant argued on appeal that the trial court erred to overrule his objection that the State used a peremptory challenge to strike an African-American prospective juror from service on his petit jury in violation of "Batson v. Kentucky." The court of appeals agreed, finding that at least one of the prosecutor's purported explanations for the peremptory challenge was a pretext for racial discrimination, and reversed the appellant's conviction. The State petitioned for discretionary review. Upon review, the Court of Criminal Appeals concluded that the court of appeals' reliance upon "Snyder v. Louisiana" on the particular facts of this case was in error: "Simply put, the court of appeals erred to conclude that Snyder governs the facts of this case. In our view, the court of appeals' analysis went wrong" by: (1) misinterpreting the prosecutor's proffer of racially neutral explanations for striking the juror in question to include two non-demeanor-based reasons; (2) concluding that the trial court made no ruling with respect to the prosecutor's demeanor-based explanations for his peremptory challenge; and (3) shifting the burden of proof to the State, a la Snyder, to rebut an inference that these purported explanations conclusively established discrimination. View "Blackman v. Texas" on Justia Law

Appellant was convicted of the Class B misdemeanor of criminal mischief for "throwing screws and nails into the road causing flat tires." On direct appeal he argued that the evidence was insufficient to support the charges against him, namely that, that the damage to the tires was the result of criminal activity. The Supreme Court granted review to clarify that the common-law corpus-delicti rule exists only in confession cases. Because the circumstantial evidence was sufficient under "Jackson v. Virginia" to prove that appellant committed the crime of criminal mischief, the Supreme Court affirmed. View "Carrizales v. Texas " on Justia Law

Appellant was convicted by a jury of capital murder and sentenced to life imprisonment without the possibility of parole. At trial, appellant sought to cross-examine two State's witnesses for bias by informing the jury of the specific felony charges (and concomitant ranges of punishment) the witness then faced in Harris County. However, the trial court limited his cross-examination to exposing the fact that the witnesses stood accused only of certain unspecified "felonies." On appeal, the appellate court rejected appellant's claim that the trial court's ruling violated his right under the Confrontation Clause to effectively cross-examine adverse witnesses and affirmed the conviction. In his petition for discretionary review, appellant urges the Court of Criminal Appeals to reverse the court of appeals on the ground that "[m]erely informing the jury that the State's witnesses had pending felony indictments is insufficient to accomplish what the Sixth Amendment right of confrontation intends[.]" Finding no reversible error, the Court affirmed. View "Johnson v. Texas" on Justia Law

Appellant Nilda Rodriguez was charged with felony murder for the death of her two-month-old son. She was convicted and sentenced to 30 years in prison. Appellant appealed, initially challenging the validity of the indictment. The court of appeals, however, determined that she had not preserved this issue for appellate review. Instead, the court of appeals requested supplemental briefing on whether it should analyze the sufficiency of the evidence to prove that Appellant committed "an act clearly dangerous to human life in the course of committing the felony of injury to a child." Concluding that the jury could have reasonably inferred that Appellant committed acts that were clearly dangerous to human life in the process of starving her son, the court of appeals held the evidence to be legally sufficient to support the conviction. On appeal, the Court of Criminal Appeals concluded there was no evidence presented in this case that Appellant committed any affirmative "act" in the starvation of her child. The evidence showed only her omissions caused the infant's death, rather than any act clearly dangerous to human life, as required by the statute. Therefore, the evidence was insufficient to support Appellant's felony murder conviction and it must be overturned. However, because the jury necessarily found Appellant guilty of the underlying felony of injury to a child and the evidence is sufficient to support this finding of guilt, the judgment was remanded to be reformed to reflect this. View "Rodriguez v. Texas" on Justia Law

Appellant Mark Fleming was charged with four counts of aggravated sexual assault. He filed a motion to quash the indictment on the basis that the aggravated sexual assault statute was unconstitutional for failing to require the State to prove that he had a culpable mental state related to the victim's age and for failing to recognize an affirmative defense based on the defendant's reasonable belief that the victim was 17 years of age or older. The trial court denied the motion. Appellant entered a plea of "no contest," filed an application for community supervision, and invoked his right to have the jury determine punishment. On the second day of testimony, one of the jurors informed the court that his son had dated the victim. In order to avoid a mistrial, the State and Appellant entered into a plea agreement for a ten-year probated sentence. Appellant appealed the trial court's denial of his motion to quash. The court of appeals overruled Appellant's federal constitutional claims and affirmed the trial court's judgment. We remanded the case to the court of appeals to consider Appellant's state constitutional claims, and the court of appeals again affirmed the trial court. Appellant filed a petition for discretionary review, which the Court of Criminal Appeals granted to consider whether Penal Code Section 22.021 is unconstitutional under the Due Process Clause of the Fourteenth Amendment and the Due Course of Law provision of the Texas Constitution because it failed to require the State to prove that the defendant had a culpable mental state regarding the alleged victim's age, and failed to recognize an affirmative defense based on the defendant's reasonable belief that the alleged victim was 17 years of age or older. Finding the statute constitutional, the Court of Criminal Appeals affirmed the court of appeals. View "Fleming v. Texas" on Justia Law

Appellant was convicted in 2012 of capital murder, specifically the intentional murder of Nancy Weatherly in the course of committing or attempting to commit burglary or robbery. Based upon the jury's answers to 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. Appellant raised eighteen points of error in this automatic appeal. The Court of Criminal Appeals found all to be without merit and affirmed the trial court's judgment and sentence of death. View "Soliz v. Texas" on Justia Law

Although applicant Frank Navarijo provided some new evidence in support of his claim that he was actually innocent of the offense of aggravated sexual assault of a child, the Court of Criminal Appeals concluded that he failed to meet this standard because his new exculpatory evidence, which came in the form of a recantation from the complainant some thirteen years after his conviction, did not unquestionably establish his innocence when that evidence was considered in light of other incriminating evidence in the record. Though the habeas court in this case determined that the complainant's recantation testimony was more credible than her trial testimony and recommended granting relief on that basis, the Court disagreed with the habeas court's assessment that the matter of a recanting witness's credibility is the sole deciding factor in an actual-innocence case, and further disagreed with its related determination that applicant has unquestionably established his innocence under "Ex parte Elizondo," 947 S.W.2d 202, 206, 209 (Tex. Crim. App. 1996). View "Ex parte Frank Navarijo" on Justia Law

A jury convicted appellant Juan Guerra of the offense of unlawful use of a criminal instrument with the intent to commit the offense of aggravated kidnapping or aggravated sexual assault and assessed punishment of twenty years' confinement. The jury also found that appellant personally used or exhibited a deadly weapon, specifically a firearm, during the commission of the offense. On direct appeal, appellant claimed that the trial court erred when it denied his motions to suppress evidence that was obtained from the initial stop of his vehicle and his subsequent detention. The court of appeals overruled that claim and ultimately affirmed the judgment of the trial court. Finding no reversible error, the Court of Criminal Appeals affirmed. View "Guerra v. Texas" on Justia Law

Appellee Mark Meru was convicted of burglary of a habitation and sentenced to 25 years in prison. He filed a motion for new trial, complaining that the trial court erred in refusing to give the requested jury instruction on the lesser-included offense of criminal trespass. The trial court granted appellee's motion for new trial. The State appealed, arguing that criminal trespass could not be a lesser-included offense of burglary because trespass required intrusion of the defendant's entire body, while burglary only requires a partial intrusion. The court of appeals affirmed the trial court's order for a new trial. The Supreme Court disagreed with the court of appeals that Appellee was entitled to an instruction on the lesser-included offense of criminal trespass and reversed.View "Texas v. Meru" on Justia Law

Appellant Rodney Anderson was charged with possession of methamphetamine with intent to deliver, and aggravated assault of a public servant. The jury found him guilty, and he was sentenced to 40 years for the possession offense, and life imprisonment for the aggravated assault. Appellant appealed, arguing that the evidence was legally insufficient to support his conviction of aggravated assault of a public servant. The court of appeals held that a rational jury could find that Appellant was guilty of aggravated assault of a public servant under the conspiracy theory of party liability. After granting appellant's petition for discretionary review, the Supreme Court concluded that the evidence was sufficient to support appellant's conviction for the aggravated assault charge under the conspiracy theory of the law of parties. Therefore the Court affirmed the appellate court's decision.View "Anderson v. Texas" on Justia Law