Justia Constitutional Law Opinion Summaries

Appellant Dedric Jones was convicted of the offense of assault on a family member, and because he had previously been convicted of such an offense, this repeat offense was a third degree felony. Appellant pled true to two additional prior felony enhancement counts, and the trial court assessed his punishment at confinement for twenty-five years in the penitentiary. The court of appeals reversed the conviction, holding the trial court erred in disallowing a certain line of questioning during Appellant’s cross-examination of the principal witness against him and it was not harmless beyond a reasonable doubt. Having reversed the conviction on this basis, the court of appeals declined to address Appellant’s second point of error. In its petition for discretionary review, the State argued the court of appeals erred on both counts: in concluding both that constitutional error occurred and that any constitutional error was not harmless. The Texas Court of Criminal Appeals reversed the court of appeals’ judgment on the basis of the second, concluding that, while constitutional error did occur, it was harmless beyond a reasonable doubt. View "Jones v. Texas" on Justia Law

Appellee Juan Martinez, Jr. was indicted for intoxication manslaughter. He moved to suppress evidence, challenging the State’s seizure and search of vials of his blood which were previously drawn at a hospital for medical purposes. The trial court granted the motion, and the court of appeals affirmed. The Texas Court of Criminal Appeals concluded that because, under the facts of this case, Appellee had a privacy interest in the private facts contained in his blood and because the State’s acquisition and subsequent testing of the blood went beyond the scope of the hospital’s blood draw, Appellee’s Fourth Amendment right to be free from unreasonable searches and seizures was violated, and the trial court correctly granted his motion to suppress. View "Texas v. Martinez" on Justia Law

Appellee Craig Doyal was the Montgomery County, Texas Judge, and as such, he was a member of the Montgomery County Commissioners Court. He was indicted for violating a provision of the Texas Open Meetings Act (TOMA), which made it a crime if a member or group of members of a governmental body “knowingly conspires to circumvent this [the Act] by meeting in numbers less than a quorum for the purpose of secret deliberations." The Texas Court of Criminal Appeals concluded that provision was unconstitutionally vague on its face. Consequently, the Court reversed the court of appeals and affirmed the trial court's judgment dismissing the prosecution. View "Texas v. Doyal" on Justia Law

Appellant William Rhomer was convicted by jury of felony murder for causing the death of another while committing felony driving while intoxicated. He was sentenced to seventy-five years in prison. The court of appeals affirmed. The Texas Court of Criminal Appeals granted Appellant’s petition for discretionary review to decide whether an accident reconstruction expert could testify about a specific type of accident reconstruction in which he had no formal training and whether accident reconstruction should be governed by the tests announced in Kelly v. Texas (824 S.W.2d 58 (1992) or Nenno v. Texas, 970 S.W.2d 549 (1998) for evaluating the reliability of the expert testimony. The Court determined the Nenno test was applicable, and that: (1) the field of accident reconstruction was a legitimate one; (2) the subject matter of the expert's testimony was within the scope of that field; and (3) his testimony properly relied upon and utilized the principles involved in the field, i.e., examining the physical evidence in the context of the crash site to draw conclusions about the location and cause of the crash. The Court therefore affirmed the court of appeals. View "Rhomer v. Texas" on Justia Law

The Office of Capital and Forensic Writs (OCFW), on behalf of Appellant Justen Hall, sought DNA testing on a power cord that was wrapped around the victim's neck. Appellant was convicted of the murder of Melanie Billhartz, whom he killed to prevent police from discovering a gang drug house. Among the details contained in Appellant’s confession was the fact that Appellant had used an “extension cord” to strangle the victim and that the cord was wrapped around the victim’s neck several times. Appellant’s confession stated that he got the extension cord from the drug house. The confession also stated that an associate used a machete to chop off fingers from the victim’s right hand. An autopsy showed that a black, three pronged power cord was wrapped around the victim’s neck three times and tied tightly. Her nasal bones were fractured, and she had multiple fractures of the lower jaw bone, fractures in her right hand, a fractured rib, cutting or sawing in the fingers area of her right hand, and fingers missing from her right hand. OCFW contended the power cord could be analyzed for touch DNA and that such an analysis could show that someone other than Appellant used the murder weapon. To meet its burden to show that an exculpatory result on such a test would make a difference in Appellant’s case, OCFW argued the evidence connecting Appellant to the murder was weak, pointing to the lack of physical or forensic evidence connecting Appellant to the murder, Appellant’s confession, and the other testimony against him as unreliable. The Texas Court of Criminal Appeals concluded OCFW did not show by a preponderance of the evidence that Appellant would not have been convicted if exculpatory results had been obtained in the testing that was being requested. The Court also concluded OCFW did not show by a preponderance of the evidence that a request for such testing was not made to unreasonably delay the execution of Appellant’s sentence. Consequently, the Court upheld the trial court’s decision to deny testing. View "Hall v. Texas" on Justia Law

Appellant Christian Sims was charged with murder. He filed a pretrial motion to suppress evidence of real-time location information used to track his cell phone by “pinging” it without a warrant. Using that information, police found and arrested him. In his motion to suppress, Appellant argued that the police violated the Fourth Amendment when they searched his phone for real-time location information. He also contended that the search violated the federal Stored Communications Act (the SCA), and articles 18.21 and 38.23(a) of the Texas Code of Criminal Procedure. The trial court denied Appellant’s motion, and Appellant pled guilty pursuant to a plea bargain. The judge sentenced him to 35 years’ confinement. As part of the agreement, he reserved the right to appeal the trial court’s ruling. The court of appeals affirmed the ruling of the trial court. Appellant filed a petition for discretionary review by the Texas Court of Criminal Appeals, which was granted on two grounds: (1) whether suppression is a remedy for a violation of the SCA or Article 18.21; and (2) whether a person was entitled to a reasonable expectation of privacy in real-time CSLI records stored in a cell phone’s electronic storage. The Court concluded suppression was not an available remedy under the Stored Communications Act unless the violation also violated the United States Constitution. And suppression was not an available remedy for a violation of Article 18.21 unless the violation infringed on the United States or Texas constitutions. Under the facts of this case, Appellant did not have an expectation of privacy in the real-time location information stored in his phone. Therefore, the Court affirmed the court of appeals' judgment. View "Sims v. Texas" on Justia Law

Appellee Roger Martinez sought to suppress challenging the legality of his arrest for public intoxication. The motion was granted by the trial court, and the court of appeals affirmed. Because there was probable cause to arrest Appellee for public intoxication, the Texas Court of Criminal Appeals reversed the judgment of the court of appeals and remanded the case to that court for further proceedings. "[E]ven if the State failed to prove that Officer Quinn personally had probable cause to arrest Appellee, and there was no evidence that he was directed to arrest Appellee, the sum total of the knowledge of Officers Guerrero, Ramirez, and Quinn amounted to probable cause. Appellee’s motion to suppress should have been denied." View "Texas v. Martinez" on Justia Law

Christopher Braughton was convicted of murder. On appeal, he challenged the sufficiency of the evidence presented against him, and argued the trial court erred in instructing the jury by omitting a lesser-included offenses instruction on felony deadly conduct. At trial, Braughton acknowledged shooting the complainant, Emmanuel Dominguez, but he claimed that he did so because he reasonably believed the use of such force was immediately necessary to protect himself and his father against Dominguez’s attempted use of deadly force. The jury rejected Braughton’s theory, convicted him of murder, and assessed a sentence of twenty years’ imprisonment. The Texas Court of Criminal Appeals concluded that, viewing the evidence in the light most favorable to the verdict and deferring to the jury’s credibility determinations and its resolution of the conflicting testimony, the evidence supported a rational jury’s rejection of appellant’s self-defense and defense of third person claims, and thus the evidence was legally sufficient to uphold his conviction for murder. Furthermore, assuming it was error to deny the instruction on felony deadly conduct, the Court determined Braughton was not harmed by any such error in the trial court’s charge. View "Braughton v. Texas" on Justia Law

Applicant Steven Chaney was convicted of murder and was sentenced to life imprisonment and fined $5,000. His conviction was affirmed on appeal. He claimed he was entitled to relief because: (1) new scientific evidence contradicted bitemark-comparison evidence relied on by the State at trial; (2) his conviction was secured using false evidence; (3) the State violated Brady v. Maryland, 373 U.S. 83 (1963); and (4) he was actually innocent. The State and habeas court agreed Chaney was entitled to relief on all grounds. After reviewing the record, the Texas Court of Criminal Appeals concurred: “Each piece of the State’s trial evidence is questionable ‘or has since been undermined or completely invalidated.’” When weighing Chaney’s newly discovered evidence against the State’s trial evidence, the Court concluded Chaney had shown by clear and convincing evidence that “no reasonable juror would have convicted [him] in light of the new evidence.” Chaney had proven that he was actually innocent. His judgment of conviction was set aside, and Chaney was remanded to the custody of the Sheriff of Dallas County to answer the charges as set out in the indictment. View "Ex parte Steven Chaney" on Justia Law

The Court of Appeals reversed appellant Cody French’s conviction for the aggravated sexual assault of a child. The appellate court held the trial court erred in not giving a unanimity instruction to the jury as to which orifice Appellant penetrated with his sexual organ. The court of appeals concluded appellant properly objected to the instruction, and it applied a “some harm” analysis under Almanza v. Texas, 686 S.W.2d 157 (Tex. Crim. App. 1985). The Texas Court of Criminal Appeals granted the State’s petition for discretionary review to address two issues: (1) whether appellant failed to preserve error by not leveling an appropriate objection to the jury charge at trial; and (2) whether appellant suffered any level of harm - either “some” or “egregious” - as a result of the trial court’s jury charge. The Texas Court of Criminal Appeals reversed the Court of Appeals. The Court found “overwhelming evidence” presented at trial that Appellant contacted and penetrated J.F.’s anus with his sexual organ on multiple occasions, in several different locations. The State said nothing during its final argument to encourage the jury to convict Appellant of genital-to-genital contact and/or penetration. And for his part, appellant offered no defense specifically tailored to suggest that he only contacted and/or penetrated J.F.’s sexual organ and not her anus. Appellant’s defense was that he did not sexually assault J.F. at all. “All of this suggests to us that the erroneous jury instruction in this case was not ‘calculated to injure the rights of the defendant,’” and that any harm resulting from the error was purely theoretical, not actual. As a result, Court held that the record fails to support the court of appeals’ conclusion that Appellant suffered “some” harm from the trial court’s failure to instruct the jury that it must be unanimous with respect to which of J.F.’s orifices was penetrated. It therefore reversed the judgment of the court of appeals and remanded the case for further proceedings. View "French v. Texas" on Justia Law