Justia Constitutional Law Opinion Summaries

In June 2013, a jury convicted appellant Willie Jenkins of capital murder for aggravated rape in November 1975. He was given the death sentence. In this automatic appeal to the Court of Criminal Appeals, he raised nineteen alleged points of error. After reviewing all of them, the Court concluded none had merit, and affirmed the trial court's judgment. View "Jenkins v. Texas" on Justia Law

Appellee Olin Robinson, and his wife, Floria were tried together for offenses arising out of a traffic stop. Deputy Bobby Doelitsch activated his overhead lights after he observed a vehicle fail to stop completely at a stop sign and fail to properly signal a turn. Floria was driving. The deputy observed that she did not stop, but continued for three and a half blocks before turning into her own driveway and finally stopping at the back of her house. Floria, ignoring the deputy’s request that she remain in the truck, exited the pickup, and tried to reach its bed. The deputy lowered the top of the bed cover on Floria’s hand to stop her. She then interfered with the deputy’s efforts to keep Appellee inside the truck. Deputy Doelitsch arrested Floria, which prompted Appellee to punch him. The couple were tried together. A jury found Floria guilty of evading arrest or detention with a vehicle and imposed punishment of two years’ confinement. For his part, Appellee was found guilty of third-degree felony assault on a public servant and received four years' imprisonment. Appellee began serving his sentence, and, that same day, filed a motion for continuing jurisdiction community supervision (“shock probation”). Thirty-seven days later, the trial court entered its order granting Appellee shock probation for four years. The State filed a notice of appeal forty-nine days after Appellee began serving his sentence. On its review of the State’s appeal, the court of appeals first recognized its jurisdiction to hear the appeal and then held that the trial court erred in granting Appellee’s motion for shock probation without holding a hearing. The Court of Criminal Appeals addressed the question of whether a court of appeals had subject-matter jurisdiction to hear the State's appeal of the trial court's grant of shock probation. If so, did the pendency of that State’s appeal deprive the trial court of subject-matter jurisdiction to consider a motion for shock probation after the mandate has issued on that appeal? The Court responded, yes and no: the State could appeal a grant of shock probation, but that appeal stays the proceedings in the trial court. Given the stay in the proceedings, the trial court’s order placing Appellee on shock probation is valid. The Court of Criminal Appeals therefore reversed the court of appeals and entered judgment affirming the shock probation order of the trial court. View "Texas v. Robinson" on Justia Law

Appellant Gregory Henley was found guilty by a jury of misdemeanor assault causing bodily injury to a family member. He was sentenced to confinement for 200 days. On appeal, he contended that the trial court excluded evidence that appellant sought to introduce in support of his claim of defense of a third person. Specifically, appellant claimed that he was justified in pulling his ex-wife out of her car by her hair, punching her in the face several times (resulting in two severe black eyes and several cuts and bruises), and hitting her head against the concrete driveway, because he was concerned that his ex-wife was not a fit parent and wanted to protect his two sons from the possibility of being harmed at some future time by people who were not present at the time of the assault. The Second Court of Appeals concluded that appellant should have been able to present evidence in support of this purported justification defense. The Court of Criminal Appeals disagreed: appellant’s claim in no way constituted a valid claim of defense of a third person. "Even if appellant’s concerns were legitimate, the evidence he sought to introduce did not give rise to any type of justification defense. Appellant’s ex-wife posed no immediate threat to his sons. In fact, no one posed an immediate threat to his sons. The evidence appellant sought to introduce in support of his purported justification defense was irrelevant. Evidence that is not relevant is inadmissible." The Court reversed the decision of the court of appeals and reinstated appellant’s conviction. View "Henley v. Texas" on Justia Law

In this case, the victim, Gonzalo Gonzalez, threw something at Appellant Francisco Duran, Jr. and his friends. Later that same day, Appellant and his friends retaliated by breaking into Gonzalo’s apartment and throwing a DVD player at him. A jury convicted Appellant of both burglary of a habitation and aggravated assault in two separate counts. The jury found Appellant guilty of both counts, but the State abandoned the aggravated assault conviction prior to the punishment phase of the trial. The issue on appeal to the Court of Criminal Appeals was whether the court of appeals erred by: (1) upholding the conviction on the aggravated assault charge even though the State had abandoned that charge prior to punishment; and (2) upholding the trial court’s modification to the judgment to include a deadly-weapon finding. The Court reversed, finding the court of appeals should have vacated the conviction for aggravated assault because the State unequivocally abandoned the charge in the middle of trial and after jeopardy had attached. The Court disagreed with the State that the trial court could have relied upon the abandoned jury verdict in the aggravated assault case to support the entry of a deadly weapon finding in Appellant’s burglary case. View "Duran v. Texas" on Justia Law

In 2009, John Anthony pleaded guilty to an indictment alleging aggravated sexual assault of a child younger than fourteen years old in exchange for the State’s recommendation for deferred-adjudication community supervision. Accepting the plea agreement, the trial judge deferred a guilty finding and placed Anthony on an eight-year term of deferred-adjudication community supervision. The judge’s deferred-adjudication order listed the victim’s age as three years old at the time of the assault. In 2013, the State moved to adjudicate alleging Anthony violated his community supervision’s terms and conditions. The judge found the violations true, found Anthony guilty, and sentenced him to life imprisonment. The judgment again noted that the victim was three years old at the time of the assault. The court of appeals found that the trial judge had no authority to grant Anthony deferred adjudication because the judge’s deferred-adjudication order contained a finding that the victim was three years old. From this conclusion, the court found that Anthony was prejudiced by counsel’s deficient performance in advising him on the offense’s punishment range. After review, the Court of Criminal Appeals held that the judge properly imposed deferred adjudication. The Court reversed the court of appeals. View "Anthony v. Texas" on Justia Law

Appellant was convicted of driving while intoxicated. His conviction was based in part upon evidence obtained as a result of a warrantless mandatory blood draw. The court of appeals reversed appellant’s conviction on the basis that drawing appellant’s blood without a warrant violated the Fourth Amendment. In its petition for discretionary review, the State argued, among other things, that appellant failed to preserve error with respect to this Fourth Amendment complaint. The Court of Criminal Appeals agreed, because appellant never obtained a ruling on this complaint. Consequently, the Court reversed the judgment of the court of appeals. View "Smith v. Texas" on Justia Law

Applicant was the ringleader of a group that burglarized dozens of apartments and condominiums in and around the Uptown area of Dallas in 2007 and 2008. A jury convicted Applicant of engaging in organized criminal activity for his role in the “Uptown burglaries” and sentenced him to 65 years in prison. In his application for writ of habeas corpus, Applicant alleged he was entitled to a new punishment hearing based upon trial counsel’s deficient performance during both the guilt-innocence and punishment phases of trial. While the Court of Criminal Appeals agreed that Applicant’s trial counsel failed to adequately investigate and present mitigating evidence, Applicant failed to demonstrate a reasonable probability that the result of the punishment proceedings would have been different. Consequently, the Court denied habeas. View "Ex parte West" on Justia Law

A jury found Appellant Ronnie Dabney guilty of manufacturing methamphetamine, and he was sentenced to 30 years in prison. He appealed the conviction, arguing that the trial court erred in admitting evidence of a prior unadjudicated offense of manufacturing methamphetamine because the State failed to give proper notice under Rule of Evidence 404(b). The court of appeals held that the evidence was inadmissable and reversed the trial court’s judgment. The Court of Criminal Appeals reversed. Appellant’s defense that he did not know that there was a methamphetamine lab on his property opened the door to the admission of evidence that officers had previously found a methamphetamine lab on his property. Under the "doctrine of chances," Appellant’s defense that he found himself in an unfortunate, highly unlikely situation became less credible when presented with evidence that he was found in that exact same situation before. Because Appellant presented his defensive theory in opening statements, the State could use extraneous-offense evidence to rebut this theory in its case-in-chief rather than waiting until the defense rested. View "Dabney v. Texas" on Justia Law

Appellant Steven Cole was tried for manslaughter. The judge overruled Cole's motion to suppress evidence obtained by a warrantless blood draw. Holding that the record did not establish exigent circumstances, the court of appeals reversed the trial court’s judgment. The Court of Criminal Appeals concluded that the record established circumstances rendering obtaining a warrant impractical and that the warrantless search is justified under the exigency exception to the Fourth Amendment’s warrant requirement. The court of appeals was accordingly reversed and the case remanded for further proceedings. View "Cole v. Texas" on Justia Law

Daniel Weems moved to suppress the results of a warrantless blood draw at his trial for felony driving-while-intoxicated. The request was denied, but the court of appeals reversed. The appellate court held, among other things, that the State failed to establish that Weems’s warrantless blood draw was justified by exigent circumstances. After review, the Court of Criminal Appeals agreed and affirmed the court of appeals’ judgment. View "Weems v. Texas" on Justia Law