Justia Constitutional Law Opinion Summaries

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

Appellant Anthony Carter was convicted by jury of possession of a Penalty Group 2-A controlled substance, with intent to deliver. He was subsequently sentenced to 90 years in prison and received a $100,000 fine. The court of appeals affirmed his conviction. The Texas Court of Criminal Appeals granted Appellant’s petition for discretionary review to determine whether, in a legal sufficiency analysis, a reviewing court could uphold a conviction if expert testimony as to certain technical elements of an offense was merely conclusory. Having concluded that the testimony in this case was not merely conclusory, the Court affirmed. View "Carter v. Texas" on Justia Law

Appellant Harold Holoman was convicted by jury of misdemeanor assault. The trial judge allowed the State, at the punishment phase of trial, to prove an otherwise-elemental prior conviction that caused Appellant to be convicted of a third degree felony and subject to that felony range of punishment. Appellant argued on appeal that, because the jury found him guilty of a misdemeanor, it was too late for the State to prove that kind of a fact at the punishment phase. The court of appeals agreed, vacated Appellant’s sentence, and remanded for resentencing within the misdemeanor range. The Texas Court of Criminal Appeals concurred with the court of appeals and affirmed its judgment. View "Holoman v. Texas" on Justia Law

Appellant Juan Carlos Flores robbed a convenience store, pretending he had a gun. The “gun,” however, was an electric drill covered in plastic bags with a black sleeve over the drill bit. Believing the drill was a gun, the store owner gave Appellant the money from the register. The issue presented for the Texas Court of Criminal Appeals' review was whether the evidence was legally sufficient to support the finding that the drill was a deadly weapon within the meaning of that term as defined in the Texas Penal Code, when Appellant never attempted to strike, stab, or “drill” anyone, nor did he threaten to do so. The Court concluded there was insufficient evidence to permit a jury to rationally conclude that Appellant used or intended to use the drill in a manner that was capable of causing death or serious bodily injury. The trial court's judgment was reversed, as was the court of appeals' judgment which upheld Appellant’s conviction for aggravated robbery based on his use or exhibition of a deadly weapon. The matter was remanded to the trial court for reformation of Appellant’s judgment to reflect a conviction for the second-degree felony offense of robbery, and for a new trial on punishment. View "Flores v. Texas" on Justia Law

The court of appeals reversed a trial court's second punishment hearing granted pursuant to a writ of habeas corpus. Appellant James Harbin, II was eighteen years old when he shot and killed his father in 1991. The issue at the time of his first trial was whether appellant killed under the immediate influence of sudden passion arising from adequate cause. In the guilt phase of appellant's first trial, the jury charge defined "sudden passion" and "adequate cause," and instructed the jury if it had a reasonable doubt about murder, it would "next consider whether the defendant is guilty of the lesser offense of voluntary manslaughter," which was in accordance with the statute then in effect. Twenty-three years later, appellant sought a new punishment hearing for the State's failure to disclose favorable information about the father's psychiatric history and for defense counsel's ineffective investigation and presentation of mitigating evidence. In the pendency of the new punishment hearing, the law changed. At the second hearing, appellant request a jury instruction on sudden passion under the 1994 law. The trial court denied the request. The court of appeals reversed and remanded for a third punishment hearing. The Texas Court of Criminal Appeals granted the State's petition for discretionary review to determine whether the court of appeals erred in applying the 1994 statute to the offense committed in 1991. The Court concluded the court of appeals erred and reversed its judgment. View "Harbin v. Texas" on Justia Law