Justia Constitutional Law Opinion Summaries

The State charged appellant with one count of making a false statement to obtain property or credit, three counts of tampering with a governmental record, and one count of falsely holding oneself out as a lawyer. Two of the five counts, the making a false statement to obtain property or credit count, and one of the tampering with a governmental record counts, were state-jail felonies. These two counts were the offenses at issue in this appeal: if a defendant pleads true to an enhancement paragraph, can a court of appeals imply a trial court’s finding of true regarding that prior conviction used for enhancement when the trial judge, in his own words, refused to make such a finding? All counts were enhanced by the same two prior felony convictions. The first enhancement paragraph reflected appellant’s 1992 state conviction for credit-card abuse; the second reflected her 1990 federal conviction for mail fraud. Appellant entered an open plea. She judicially confessed to all five counts and pleaded true to both enhancement paragraphs. The trial court found the evidence sufficient to find appellant guilty, but it continued the hearing to the next day “to make a determination whether or not a finding of guilt should be made, or whether any finding of guilt should be deferred for a period of years.” The Court of Criminal Appeals held that the court of appeals could not imply the trial court's finding of true regarding the prior conviction used for enhancement when the trial judge refused to make such a finding. The Court therefore reversed the court of appeals and remanded this case for a new punishment hearing. View "Donaldson v. Texas" on Justia Law

In 2012, law-enforcement officers in Victoria were investigating appellee Michael Rendon on suspicion of drug activity. One day, several officers and a trained drug-detection dog went to the apartment complex where appellee lived. The issue this appeal presented for the Court of Criminal Appeals centered on whether it constituted a search within the meaning of the Fourth Amendment for law enforcement to bring the drug-detection dog directly to appellee's front door for the purpose of conducting a narcotics sniff. The Court concluded that the officers' use of the dog sniff resulted in a physical intrusion into the curtilage that exceeded the scope of any express or implied license, thereby constituting a warrantless, unconstitutional search. The Court affirmed the court of appeals and trial court's rulings granting appellee's motions to suppress. View "Texas v. Rendon" on Justia Law

Appellant Randall Mays was convicted for the capital murder of a law enforcement officer, for which he received a death sentence. He challenged his competency to be executed, but the trial court denied his motion because he failed to make a substantial showing of incompetence. On appeal to the Court of Criminal Appeals, Mays argued he did indeed make a showing of incompetence, and the Court agreed with him. Because the Court held as such, it set aside the trial court's denial of relief and remanded this case for competency proceedings. View "Mays v. Texas" on Justia Law

Appellee John Wachtendorf, Jr. was charged with the felony offense of Driving While Intoxicated. According to the district clerk’s file-mark, on January 16, 2014, Appellee filed a motion to suppress the results of a test for blood alcohol concentration following the extraction of blood at the time of his arrest. At the conclusion of a hearing on February 14, 2014, the trial court took the motion to suppress under advisement. On July 7, 2014, the hearing reconvened, and the trial court orally announced that it intended to grant Appellee’s motion. The docket sheet reflected that the trial court actually signed an order to that effect on the same day. The State contended, however, that the trial court did not sign the order in open court, and the Reporter’s Record did not clearly indicate that it did. Rather, the Reporter’s Record showed that, in response to the State’s request for written findings of fact and conclusions of law, the trial court directed Appellee to prepare proposed findings and conclusions and adjourned the hearing. Appellee did not immediately file the requested findings and conclusions. The issue for the Court of Criminal Appeals’ review this case was whether the time for filing a notice of appeal from an order adverse to the State should begin to run with the trial court’s signing of that order if the State received no timely notice that the order had been signed. The State argued that it was not notified that the trial court had signed an order granting Appellee’s motion to suppress until the period for filing its notice of appeal had expired. Having received no notice of this triggering event, the State filed an untimely notice of appeal, and the Court of Appeals dismissed its appeal for want of jurisdiction. Finding no reversible error in the Court of Appeals’ decision, the Court of Criminal Appeals affirmed. View "Texas v. Wachtendorf" on Justia Law

In October 2013, a jury convicted appellant Matthew Johnson of capital murder for intentionally causing the death of Nancy Harris, a seventy-six-year-old convenience store clerk, by setting her on fire while he was robbing or attempting to rob her. For this crime, appellant was sentenced to death. In his automatic, direct appeal to the Court of Criminal Appeals, appellant raised sixty-five points of error. After reviewing each, the Court found no merit to any of them, and affirmed appellant’s conviction and sentence. View "Johnson v. Texas" on Justia Law

Applicant Kemos Barnaby plead guilty in a package deal to four separate offenses of possession of a controlled substance with intent to deliver and was sentenced to four concurrent fifty-year sentences. In his application for writ of habeas corpus, applicant challenged only the voluntariness of his plea to the offense charged in Case No. 09-04-04192-CR. There, the forensic technician assigned to analyze the seized substance was Jonathan Salvador, who was known to have falsified test results. The Court of Criminal Appeals remanded to the trial court so that the parties could present arguments on what standard of review was appropriate for examining materiality. The Court held that materiality of false evidence in the context of a guilty plea should be examined under the same standard used to assess materiality of counsel’s deficient performance in the context of a guilty plea: if applicant had known that the evidence was false he would not have plead guilty but would have insisted on going to trial. The Court inferred that the laboratory report in applicant’s case was falsified, the Court nevertheless found that its falsity was not material to his decision to plead guilty, and denied relief. View "Ex party Barnaby" on Justia Law

Appellee Juan Reyes petitioned for habeas relief, attacking a judgment that imposed community supervision. In support of his application, appellee raised five grounds. Evidence supporting all of these grounds was submitted in either affidavit form or through witnesses at a live hearing. The trial court granted relief on the first ground and did not address the remaining four grounds. Holding that the trial court erred in granting relief on the first ground, the court of appeals reversed the trial court’s judgment and rendered judgment reinstating the guilty plea. The Court of Criminal Appeals concluded that the court of appeals should have remanded the case to the trial court to resolve appellee’s remaining claims. Consequently, it reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "Texas v. Reyes" on Justia Law

Relator was convicted of capital murder for killing his two children, Javier and Diana Medina. The Office of Capital Writs filed an initial writ of habeas corpus application with the convicting court on relator’s behalf. Counsel raised several Cronic- and Strickland-based claims of ineffective assistance of trial counsel, predicated on trial counsel’s abandonment of the adversarial testing of the State’s punishment case. The habeas judge issued an order designating those claims for further development and held a hearing. Following the hearing, the State noticed its intent to call relator as a witness at the evidentiary hearing. The issue this case presented for the Court of Criminal Appeals’ review was whether the State, in a post-conviction evidentiary hearing on a writ of habeas corpus, was clearly prohibited from calling the writ applicant to testify (under a grant of both use and derivative-use immunity) about whether he was aware of and agreed to trial counsel’s strategy at the punishment stage of his capital-murder trial. Because this case was presented to the Court of Criminal Appeals as a writ of prohibition, the Court was not asked to decide the precise scope of the Fifth Amendment’s protection against self-incrimination. Instead, the issue was whether the trial court made a judicial decision or a ministerial one. Specifically, the Court had to decide whether the law on this issue was so clear that the trial court had no choice but to prohibit the State from calling relator to the stand. After examining the relevant case law regarding the scope of the Fifth Amendment from the United States Supreme Court and Texas precedent, the Court of Criminal Appeals could not say that the trial court had a ministerial duty to prohibit the State from calling relator to testify. Therefore, the Court denied the writ of prohibition. View "In re Hector Medina" on Justia Law

Appellant Cody McKay was convicted of injury to a child with the culpable mental state of criminal negligence after spilling hot water on the back of the two-year-old victim. Appellant was sentenced to two years’ imprisonment, which was then suspended, and he was subsequently placed on community supervision for five years. Appellant appealed ,arguing that there was insufficient evidence to support his conviction. The court of appeals affirmed. The Court of Criminal Appeals granted Appellant’s petition for discretionary review to consider whether the court of appeals erred in determining there was sufficient evidence of Appellant’s criminal negligence. After review, the Court concluded the evidence was insufficient to support Appellant’s conviction, and reversed the court of appeals and vacated the conviction. View "McKay v. Texas" on Justia Law

Appellant was charged with ten counts of sexual assault of a child and indecency with a child. Based on the advice of his counsel, he declined the State’s plea bargain recommending a ten-year sentence and proceeded to trial. The jury found Appellant guilty and gave him eight life sentences and one twenty-year sentence. He filed a motion for new trial claiming ineffective assistance of counsel. The trial judge granted the motion for new trial and motion to require the State to reinstate the plea bargain offer of ten years. The State reinstated the plea offer, and Appellant accepted it. The trial judge rejected the plea agreement and advised Appellant that he could withdraw his guilty plea and go to trial or accept a 25-year sentence. Appellant rejected the 25-year sentence and moved to recuse the trial judge on the basis of demonstrated prejudice. The judge voluntarily recused herself, and a new judge was assigned to the case. Appellant filed another motion to require the State to re-offer the ten-year deal. The new judge declared that the slate was wiped clean by the original judge’s recusal but that she would accept a new agreement if one were reached. The State offered a plea deal of 25 years and Appellant accepted, pleading guilty to five of the counts in exchange for the waiver of the other five counts. The judge accepted the deal and signed the judgments of conviction. Appellant appealed, claiming that he was entitled to a ten-year plea-bargain offer from the State and that the trial court was required to accept the ten-year plea agreement. Concluding that Appellant was indeed prejudiced, the court of appeals determined that the proper remedy was to require the State to reoffer the ten-year plea bargain and to have the agreement presented to a judge who had not recused herself. The court of appeals reversed the trial court and remanded the case with instructions for the State to re-offer the ten-year plea bargain. The State appealed. The Court of Criminal Appeals reversed: Appellant received everything he requested in this case: the trial judge granted his motion for new trial, granted his motion to require the State to reoffer the most favorable plea deal, and then recused herself so that a new judge could hear the case. The new judge was not required to give Appellant what the previous judge, whom he sought to recuse, had already given him. The 25-year sentence that was offered by the State, agreed to by Appellant, and accepted by the trial court was reinstated. View "Rodriguez v. Texas" on Justia Law