Justia Constitutional Law Opinion Summaries

Appellant Cornelious Matthews was charged with possession with intent to deliver cocaine. He filed a pre-trial motion to suppress the crack cocaine that officers found during a warrantless search of a van that appellant had borrowed. After hearing the evidence, the trial judge ruled that appellant's original detention was reasonable and that he lacked standing to challenge the search of the van. A jury then found appellant guilty and sentenced him to twenty-two years in prison. The court of appeals affirmed, agreeing that appellant lacked standing to challenge the van's search and upholding appellant's detention, even though it was based largely on information from an anonymous tip. The issues this case presented to the Court of Criminal Appeals was: (1) whether a person who legitimately borrows a vehicle has standing to challenge its search; and (2) if appellant's initial and continued detention was supported by reasonable suspicion. The Court concluded that, although appellant originally had standing to challenge the search of the borrowed van, he abandoned any expectation of privacy (and hence his standing) when he fled from the officers and the van. Second, the officers had reasonable suspicion to detain appellant that was not based solely on the anonymous tip, and appellant's act of fleeing increased their suspicion and further justified his continued detention to await the arrival of a drug dog. View "Matthews v. Texas" on Justia Law

Applicant Leroy Coty was charged with possession with intent to distribute at least 400 grams of a controlled substance. After the malfeasance of a laboratory technician that worked on his case was discovered, Applicant filed an application for a writ of habeas corpus. The Court of Criminal Appeals granted relief in a per curiam opinion. However, before mandate issued, the Court withdrew its opinion, granted rehearing, and issued a briefing order to the parties. The Court then issued a second opinion in which it set forth a new analytical framework to resolve claims of forensic technician misconduct. The Court then remanded the case to the habeas court to apply the principles laid out in that opinion. The habeas court issued new findings of fact and conclusions of law recommending that the Court of Criminal Appeals deny relief. After reviewing the record, the Court of Criminal Appeals agreed and denied relief. View "Ex parte Coty" on Justia Law

The issue this case presented to the Court of Criminal Appeals was whether an amendment to the evading-arrest statute in the Texas Penal Code was enacted in violation of the "single-subject rule" of the Texas Constitution, thereby rendering that enactment void. Concluding that it was not, the Court determined that the court of appeals properly upheld the trial court's denial of the pre-trial application for a writ of habeas corpus filed by appellant Richard Jones. Appellant alleged that the amendment to the evading-arrest statute that became effective on September 1, 2011, was facially unconstitutional because it was enacted in violation of Section 35 of the Texas Constitution, which states, "No bill . . . shall contain more than one subject." The Court of Criminal Appeals concluded that this bill did not violate the single-subject requirement. Therefore the Court affirmed the appellate court's judgment. View "Ex parte Jones" on Justia Law

Appellant Ramon Perez was convicted of three counts of aggravated sexual assault of a child and two counts of indecency with a child by contact. He was sentenced to life in prison for each of the three aggravated counts and twenty years in prison and a fine for each count of indecency. All sentences were to run consecutively. The Tenth Court of Appeals affirmed his sentence. Appellant was originally charged in an eleven-count indictment with four counts of indecency with a child and seven counts of aggravated sexual assault. The day before trial, the State filed a motion asking the trial court to amend the indictment by replacing the existing eleven counts with the five counts in an attached exhibit. The motion also stated, "The Defendant, by and through his attorney of record, has been notified that the State is seeking amendment of the indictment, agrees to the amendment and waives ten (10) days notice to prepare for trial ...." The State's motion was signed by appellant and his trial attorney as "Agreed." The trial court held a hearing on the motion. Appellant's trial counsel stated that he had no objections to the amendments and that they were waiving the statutorily-allowed extra time. On appeal of his convictions, however, appellant raised two issues: 1) whether the indictment was properly amended from its original eleven counts to five ; and 2) whether the trial court committed reversible error by not granting the appellant a hearing on his motion for new trial. Finding no error, the Court of Criminal Appeals affirmed the Court of Appeals. View "Perez v. Texas" on Justia Law

Applicant Robert Harleston, Jr., was serving a twenty-five-year sentence for the aggravated sexual assault of a child. In his application for a writ of habeas corpus, Applicant claimed that he was actually innocent based on the victim's alleged recantations. After conducting a live evidentiary hearing, the habeas court adopted findings of fact that the victim's recantations were credible and recommended that this Court grant relief. After independently reviewing the record, the Court of Criminal Appeals rejected the habeas court's findings that the victim's recantations were credible because those findings were not supported by the record. The Court held that Applicant failed to present clear and convincing evidence that unquestionably established his innocence. View "Ex parte Harelston" on Justia Law

Appellant, convicted of money laundering after officers found half a million dollars in cash hidden inside the speaker box of his tractor-trailer, argued on appeal to the Court of Criminal Appeals that the evidence was legally insufficient to prove that the money represented proceeds from the delivery of a controlled substance. The court of appeals, relying in part on a drug-dog alert to the cash, rejected that argument. The narrow question before the Court of Criminal Appeals was whether the conclusion that the cash money in appellant's truck was the proceeds of drug trafficking was warranted by the cumulative force of all the circumstantial evidence. "In isolation, many of the facts relied on by the State could be characterized as only somewhat probative of whether appellant's cache of cash was drug-delivery proceeds. However, we do not consider evidence myopically or point out problems with the individual, separate facts underlying the State's case because all of the evidence-both direct and circumstantial-must be evaluated as a whole by the reviewing court." After reviewing all of the evidence, the Court agreed that the cumulative force of the circumstantial evidence was sufficient to prove, beyond a reasonable doubt, that the cash was the proceeds of the sale of a controlled substance. View "Acosta v. Texas" on Justia Law

Appellant pleaded guilty to burglary of a habitation. The trial court deferred a finding of guilt and placed her on community supervision for a period of five years. The trial court twice extended her term of community supervision and, upon the state's third motion to adjudicate her guilt, assessed punishment at eight years' confinement. On direct appeal, appellant argued that the trial court lacked jurisdiction to revoke her community supervision because the state filed its third motion to adjudicate after her community supervision had expired. The court of appeals overruled these issues and affirmed the trial court's judgment. The Court of Criminal Appeals granted review of two of the three grounds that appellant raised in her petition: (1) whether the trial court lacked jurisdiction to revoke appellant's community supervision because the motion to proceed to adjudicate was filed one day after the seven and one half year period of probation ended; and (2) "[w]hen the trial court pronounces the period of community supervision as being so many years and/or so many months and then the date is not correctly calculated so that the amount of years and/or months and the ending calendar date are [not] the same, which prevails, the announcement of the year and/or months or the calendar date, the longer period regardless of the conflict, the court's intent, or some other method of resolving the conflict?" The Court concluded that its holding in "Nesbit v. Texas" set out the required end-date calculation and controlled in the event of a conflict with a specified end-date. The Court therefore sustained those grounds and reversed the court of appeals' judgment. View "Whitson v. Texas" on Justia Law

A jury convicted appellant of driving while intoxicated. The trial judge denied his motion for new trial, which alleged that outside influences were improperly brought to bear on the jury foreman. The court of appeals held that the trial court abused its discretion in denying appellant's motion for new trial alleging juror misconduct. Because appellant's "outside influence" argument misapplied the Court of Criminal Appeals' holding in McQuarrie v. Texas, the Court granted the State's petition for discretionary review. "Personal pressures [such as a fear of inclement weather or concern about a child's illness] are not 'outside influences' under Texas Rule of Evidence 606(b). Accordingly, juror testimony about these issues is not admissible." Because appellant failed to prove that the jury's verdict was tainted by juror misconduct, the trial judge did not abuse his discretion in denying appellant's motion for new trial. The Court therefore reversed the court of appeals. View "Colyer v. Texas" on Justia Law

A jury convicted appellant of aggravated robbery and assessed his punishment, enhanced with one prior felony conviction, at seventy-five years' imprisonment. On appeal, appellant argued that the prosecutor willfully violated a pre-trial discovery order and that the trial court erred in failing to exclude from jury consideration the evidence that was wrongfully withheld from his court-ordered pre-trial scrutiny. The court of appeals found that the trial court did not abuse its discretion in concluding that the prosecutor's violation of the discovery order was not willful and that exclusion of the evidence was, therefore, unnecessary. Finding no reversible error, the Court of Criminal Appeals affirmed the court of appeals. View "Francis v. Texas" on Justia Law

In consolidated cases, the issue before the Court of Criminal Appeals centered on an interpretation of the United States Supreme Court's recent decision in Miller v. Alabama, which held that the Eighth Amendment to the United States Constitution forbids sentencing schemes for juveniles in which life imprisonment without the possibility of parole is mandatory rather than based upon an individualized sentencing assessment. Appellants argued that their sentences, which the appellate courts reformed to life imprisonment, were unconstitutional because they were not afforded individualized hearings at which to present mitigating evidence. The Court concluded it did not read Miller so broadly and therefore affirmed the judgment of the appellate courts. View "Lewis v. Texas" on Justia Law