Justia Constitutional Law Opinion Summaries

In February 2014, a jury convicted Juan Balderas of capital murder committed in December 2005, for which he received the death sentence. Appeal to the Court of Criminal Appeals was automatic; Balderas raised nine issues to support overturning his sentence. Taking each in turn and finding no merit to any of those arguments, the Court affirmed the trial court's judgment and Balderas' death sentence. View "Balderas v. Texas" on Justia Law

Applicant Garcia White was sentenced to death. In a subsequent habeas application, applicant claimed that, if certain newly discovered scientific evidence had been available at trial, it would likely have changed the jury’s answers to the special issues. Applicant claimed that this new evidence entitled him to relief under Article 11.073. After review, the Court of Criminal Appeals concluded that it did not, because evidence that would have changed only punishment did not satisfy Article 11.073’s requirement that the new evidence show that applicant “would not have been convicted.” Consequently, the Court dismissed the application. View "Ex parte Garcia Glen White" on Justia Law

In 2004, Appellant Anthony Metts pled guilty to two charges of sexual assault of a child and was placed on deferred adjudication community supervision for each offense. Before Appellant entered his plea, he and a prosecutor representing the State appeared at a status hearing to waive Appellant’s right to a jury trial. The prosecutor later became a district court judge and, nine years later, she adjudicated Appellant guilty and sentenced him to ten years of confinement for each offense. On appeal, Appellant argued for the first time that the trial court’s judgments were void because the judge was constitutionally and statutorily disqualified from presiding over cases in which she had previously acted as counsel for the State. The court of appeals rejected Appellant’s assertions and affirmed the trial court’s judgments. The Court of Criminal Appeals granted Appellant’s petition for discretionary review to consider his contention that the court of appeals erred by holding that the trial judge’s prior involvement in the cases as a prosecutor did not render her constitutionally and statutorily disqualified from adjudicating Appellant’s guilt. Agreeing that the trial judge should have been disqualified, the Court vacated the judgments of the court of appeals and remanded the case for further proceedings. View "Metts v. Texas" on Justia Law

Appellant Aaron Moore was charged with Aggravated Sexual Assault of a Child. Although he was 16 years old at the time of the offense, charges were not filed until after his 18 birthday. Because Appellant was over 18 years of age when charges were filed, the State filed a petition for discretionary transfer from juvenile court to criminal district court, which was granted. The criminal district court deferred adjudication and placed Appellant on 5 years’ community supervision. Appellant appealed, claiming that the juvenile court improperly transferred the case because the State failed to show that, for reasons beyond the control of the State, it was not practicable to proceed in juvenile court before his 18th birthday as required under Family Code Section 54.02(j)(4)(A). The court of appeals vacated the trial court’s judgment, holding that the juvenile court lacked jurisdiction to transfer the case. The State filed a petition for discretionary review to the Court of Criminal Appeals, which was granted to determine whether the court of appeals’s construction of “the state” in Family Code Section 54.02(j)(4)(A) required dismissal of a case with prejudice without consideration of the factors for oppressive delay in violation of the separation of powers doctrine. Finding no reversible error, the Court affirmed. View "Moore v. Texas" on Justia Law

Appellants Kenneth and Shelley Walker were charged with and convicted of causing injury to a child when they were alleged to have immersed their granddaughter's feet in scalding hot water, causing her to suffer second-degree burns to her feet and ankles. The Walkers were sentenced to 25 years each. The court of appeals affirmed the convictions. In consolidated appeals, appellants contended that the court of appeals erred in holding that the evidence was sufficient to sustain their convictions. Specifically, appellants argued the jury’s conclusion that they intentionally immersed the child's feet in the hot water was based on the drawing of multiple unreasonable inferences and was thus too speculative to give rise to any criminal liability in this case. The Court of Criminal Appeals concluded after review of the trial court record that the evidence in this case could rationally be said to establish nothing more than a mere suspicion of wrongdoing by appellants, the evidence was insufficient to prove that either appellant engaged in the conduct at issue in this case–namely intentionally immersing the child in hot water. Therefore, the Court held that no reasonable trier of fact could have found all the elements of the offense of injury to a child beyond a reasonable doubt. Furthermore, the Court held that, given that the evidence failed to prove beyond a reasonable doubt the commission of any criminal conduct by either appellant, the convictions could not be reformed to any lesser-included offense. The Court reversed the judgments of the court of appeals and rendered judgments of acquittal. View "Walker v. Texas" on Justia Law

Shirley Copeland was charged with possession of a dangerous drug after police searched the vehicle she was in and found prescription pain medication in a plastic bag. She filed a motion to suppress, arguing that the search of the car was illegal. The trial court granted the motion and sua sponte issued findings of fact and conclusions of law. The State’s initial appeals focused on whether the police had the consent of the driver and Copeland to search the vehicle. In the first appeal, the Court of Criminal Appeals held that Copeland could not deny consent for police to search the vehicle when the driver and registered owner of the vehicle did consent to the search. In the next appeal, the Court held that the State did not procedurally default its argument at trial or on appeal that the driver freely and voluntarily gave his consent to search his vehicle. The case was remanded with instructions that the court of appeals determine if there was an alternative theory of law upon which to uphold the ruling of the trial court. Specifically, the Court of Criminal Appeals noted that, in her motion to suppress, Copeland argued that the length of her detention was unreasonable but that the State did not challenge that argument on appeal. On remand, the court of appeals held that the State procedurally defaulted the length-of-detention issue. The State appealed, and the Court of Criminal Appeals exercised its discretionary review power to determine: (1) whether the court of appeals erred when it held that the State procedurally defaulted the length-of-detention issue; and (2) whether the court of appeals properly performed the analysis as instructed. The Court of Criminal Appeals agreed with the court of appeals that the State procedurally defaulted the length-of-detention issue on appeal, and affirmed. View "Texas v. Copeland" on Justia Law

Holding that a traffic stop was illegal, the trial court granted a motion to suppress. One of the State’s arguments on appeal was that, if the police officer was mistaken about whether appellee Jose Cortez had committed a traffic offense, the traffic stop was nevertheless legal as a reasonable mistake of law under "Heien v. North Carolina," (135 S.Ct 530 (2014)). Citing precedential cases that predated "Heien," the court of appeals concluded that even a reasonable mistake about the law would not justify a stop. However, the court of appeals did not discuss Heien. After review of this case, the Court of Criminal Appeals concluded that the court of appeals failed to address every issue necessary to the disposition of this case case. Consequently, the Court vacated the decision of the court of appeals and remanded the case for reconsideration under Heien. View "Texas v. Cortez" on Justia Law

Appellant Sir Melvin Wright, Jr. was indicted for failing to register as a sex offender. On direct appeal from the revocation of “regular” community supervision, appellant contended that his sentence was illegal. He argued that the court of appeals erred in applying the habeas harm analysis from "Ex parte Parrott," (396 S.W.3d 531 (2013)) to his case on direct appeal. After review, the Court of Criminal Appeals rejected appellant’s complaint because his illegal-sentence claim on was a collateral attack on the judgment from the original plea proceeding. Consequently, the court of appeals' judgment was affirmed. View "Wright v. Texas" on Justia Law

In 2013, the Civil Rights Division of the Harris County District Attorney’s Office received a complaint alleging that appellee Jimmy Drummond, a sergeant in the Harris County Constable’s Office, engaged in official oppression when he used excessive force while arresting five individuals. Seven days after the complaint was received, and one day before the expiration of the statute of limitations, a probable-cause affidavit was presented to a magistrate who agreed with the State and authorized the issuance of a capias. That same day, an assistant district attorney charged Drummond with official oppression. About three months after the State filed the document in question, a grand jury returned an indictment based on the same allegations, but the indictment did not include tolling language. Drummond filed a motion to quash based on the lack of that language, but before the judge ruled on the motion, a grand jury returned a second indictment that included tolling language. Drummond argued that both indictments should have been quashed, and the trial court agreed. The issue for the Court of Criminal Appeals' review was whether the State successfully tolled the statute of limitations. The court of appeals agreed with the trial court that the State had not tolled the statute of limitations too, holding that, because the State was required to present an information or indictment to prosecute the Class A misdemeanor offense of official oppression, the statute of limitations was not tolled when it presented only a complaint. The Court of Criminal Appeals concluded that the document constituted a complaint and information, and the filing was sufficient to toll the statute of limitations. Accordingly, the Court reversed the court of appeals, set aside the trial court’s order granting the motion to quash, and remanded this case for further proceedings. View "Drummond v. Texas" on Justia Law

Appellant Dewan Morgan was convicted of burglary of a habitation and sentenced to sixteen years’ imprisonment. Concluding that the evidence was insufficient to support the jury finding that Appellant entered a habitation “without the effective consent of the owner,” the Court of Appeals reversed the conviction because Appellant was a "cotenant" of the apartment he broke into. The Court of Criminal Appeals disagreed with that holding because, under the facts of this case, it ran contrary to the Texas Penal Code’s definition of "owner" as a person with "a greater right to possession of the property than the actor." Appellant’s girlfriend, as the complainant, was the "owner" of the apartment because she held a greater right to possession than Appellant. And, at the time of the commission of the offense, Appellant did not have her effective consent to enter. View "Morgan v. Texas" on Justia Law