Justia Criminal Law Opinion SummariesArticles Posted in Supreme Court of Texas
Ex parte K.T.
In this consolidated appeal involving unrelated respondents who were acquitted of driving while intoxicated (DWI), the Supreme Court affirmed the judgments of the lower courts, holding that the exception to expunction did not apply in this case.Both respondents sought expunction of the records relating to their arrests, and both had a previous DWI conviction from at least three years before the arrest that led to acquittal. Separate trial courts ordered expunction of each respondent's records. The court of appeals affirmed. The Supreme Court affirmed, holding that both respondents established their entitlement to expunction and that no exception applied. View "Ex parte K.T." on Justia Law
Taylor v. Tolbert
The Supreme Court affirmed the judgment of the court of appeals that the attorney-immunity defense was inapplicable to federal wiretap claims but reversed and rendered judgment for the defendant-attorney on Plaintiffs' state wiretap claims, holding that the attorney-immunity defense was inapplicable to the federal wiretap claims but did attach to the state wiretap claims.Plaintiffs brought this private party civil suit asserting that Defendant and others had violated the federal and Texas wiretap statutes by using and disclosing illegally intercepted electronic communications. Defendant moved for summary judgment, arguing that she was immune from liability as a matter of law because Plaintiffs' claims all stemmed from her role as an attorney in a modification proceeding. The trial court agreed and rendered summary judgment for Defendant. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was entitled to summary judgment on the state wiretapping claims; but (2) Defendant was not entitled to summary judgment on the claims under the federal wiretap statute because this Court is not convinced that federal courts would apply Texas's common-law attorney-immunity defense to that statute. View "Taylor v. Tolbert" on Justia Law
In re G.S.
In this case involving a claim for wrongful imprisonment compensation under the Tim Cole Act, Tex. Civ. Proc. & Rem. Code 103.001-.154, the Supreme Court denied G.S.'s request for mandamus relief, holding that G.S. did not satisfy the Act's requirements.G.S. pleaded guilty to indecency with a child but was later granted habeas relief based on ineffective assistance of counsel. After it was discovered that G.S.'s alleged victim had fabricated the accusations and G.S. arrest and conviction were expunged, G.S. applied for wrongful imprisonment compensation under the Act. The Texas Comptroller of Public Accounts denied the application. G.S. subsequently filed his petition for writ of mandamus. The Supreme Court denied the writ, holding that G.S. did not establish his actual innocence as required by the Act, and therefore, he failed to prove his entitled to compensation under the Act. View "In re G.S." on Justia Law
Matzen v. McLane
The Supreme Court rendered judgment dismissing Petitioner's claims regarding his civil commitment as a sexually violent predator (SVP), holding that all of Petitioner's claims failed as a matter of law.Following a trial, a jury found that Petitioner was an SVP and issued a civil commitment order placing Petitioner in outpatient treatment and setting forth certain conditions. Petitioner later brought this lawsuit against the Texas Civil Commitment Office (TCCO) and the director of the office (collectively, the State), alleging that the TCCO's cost-recovery rules were invalid. The State filed a plea to the jurisdiction asserting immunity from suit. The district court dismissed all claims against the State except Petitioner's due process and takings claims. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that all of Petitioner's claims against the State failed as a matter of law and that the State's plea to the jurisdiction should have been granted in full. View "Matzen v. McLane" on Justia Law
Ex Parte R.P.G.P.
The Supreme Court reversed the judgment of the court of appeals affirming the denial of Petitioner's petition to expunge his driving while intoxicated (DWI) arrest records pursuant to Tex. Crim. Proc. Code 55.01(a)(2)(A), holding that the court of appeals erred in holding that Petitioner's DWI arrest records were not eligible for expunction under article 55.01(a)(2).At issue was whether an arrest involving multiple offenses is divisible for purposes of expunging arrest records under article 55.01. The court of appeals applied the "arrest-based" construction of the statute, under which expunction is available only if all of the offenses comprising an arrest are eligible for expunction. The Supreme Court reversed, holding (1) under article 55.01(a)(2)(A), misdemeanor offenses are eligible for expunction on an individual basis; and (2) Petitioner was entitled to partial expunction of his arrest records. View "Ex Parte R.P.G.P." on Justia Law
In re Luther
The Supreme Court granted Petitioner's petition for writ of habeas corpus and ordered that Petitioner is and shall remain discharged from custody, holding that the subject temporary restraining order's lack of specificity regarding the conduct to be restrained rendered it and the judgment of contempt and order of confinement void.Petitioner was jailed and her solely-owned business, a cosmetology salon, was fined for violating a temporary restraining order requiring them to cease and desist for operating the salon for in-person services in violation of regulations related to the COVID-19 pandemic. The trial court issued a judgment holding Petitioner and her business in contempt. Petitioner filed this habeas corpus petition arguing that she was illegally restrained because the temporary restraining order was unconstitutional and void. The Supreme Court agreed, holding (1) the temporary order was void; and (2) therefore, the contempt judgment based on that order was void as well. View "In re Luther" on Justia Law
In re Alfred Dewayne Brown
The Supreme Court conditionally granted Alfred Brown's petition for writ of mandamus challenging the determination of the Comptroller of the State of Texas denying Brown's compensation claim brought after he was found to be wrongfully convicted and imprisoned, holding that Brown was eligible for compensation under the Time Cole Act. See Tex. Civ. Prac. & Rem. Code 103.001-.154.Brown was wrongfully convicted of capital murder and sentenced to death. After serving more than twelve years behind bars, Brown was released from prison when it was determined that the prosecuting attorney withheld and suppressed exculpatory evidence. After securing a judicial declaration of actual innocence Brown sought compensation under the Act for the time he was wrongfully imprisoned. The Comptroller denied the compensation claim, concluding that the district court had jurisdiction to issue an order declaring Brown actually innocent. The Supreme Court conditionally granted Brown's petition for writ of mandamus, holding (1) Brown was eligible for compensation under the Act; and (2) the Comptroller exceeded his authority by considering matters beyond the verified documents to make a de novo jurisdictional determination. View "In re Alfred Dewayne Brown" on Justia Law
In re Commitment of Jeffery Lee Stoddard
The Supreme Court reversed the judgment of the court of appeals reversing a jury's finding that Jeffery Lee Stoddard was a sexually violent predator (SVP) and civilly committing him under Tex. Health & Safety Code chapter 841, holding that the court of appeals applied an improper standard.The court of appeals described the standard governing the factual sufficiency review in which the burden of proof was beyond a reasonable doubt the court of appeals described the standard as requiring the court to weigh the evidence in a neutral light to determined whether the jury's finding was factually insufficient or so against the great weight and preponderance as to be manifestly unjust, shock the conscience, or clearly demonstrate bias. The Supreme Court reversed, holding (1) the court of appeals applied an improper standard that allowed the court to substitute its own judgment for that of a reasonable fact-finder and incorporated a statutory element that chapter 841's text did not support; and (2) a properly conducted factual-sufficiency review in an SVP case requires the appellate court to determine whether, on the entire record, a reasonable factfinder could find beyond a reasonable doubt that the defendant is an SVP. View "In re Commitment of Jeffery Lee Stoddard" on Justia Law
In re Commitment of Jones
The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment and commitment order on the grounds that the trial court committed harmful error when it declined to submit an instruction explaining that a verdict for Defendant required only ten out of twelve votes, holding that the error was not harmful.The Supreme Court granted a motion for rehearing, withdrew its opinion and judgment of April 24, 2020, and substituted this opinion. At issue was whether a final verdict for a defendant declining to find that the defendant is a sexually violent predator (SVP) must be unanimous. Defendant requested an instruction explaining that an unanimous verdict was required to find that he was an SVP but that only ten out of twelve votes were required to find that he was not an SVP. The trial court declined to submit the requested instruction. The jury returned with a unanimous verdict finding that Defendant was a SVP. The court of appeals reversed, concluding that the trial court committed harmful error in declining to submit Defendant's instruction. The Supreme Court reversed, holding (1) the trial court erred when it denied Defendant's proffered jury instruction; but (2) the error was not harmful. View "In re Commitment of Jones" on Justia Law
In re Commitment of Gregory Jones
The Supreme Court reversed the decision of the court of appeals reversing the trial court's judgment and commitment order and reinstated the judgment of the trial court ordering Gregory Jones civilly committed as a sexually violent predator (SVP) under Tex. Health and Safety Code chapter 841, holding that the trial court erred when it declined to submit an instruction explaining that a verdict for Jones required only ten votes out of a jury of twelve, but the error was harmless.A civil-commitment trial conducted under chapter 841 provides that a verdict may be rendered by the agreement of ten members of a twelve-person jury. By statute, however, a civil-commitment verdict finding that the defendant is a sexually violent predator must be unanimous. On appeal, Jones argued that the trial court erred when it declined to submit his instruction that a final verdict for the defendant required only ten out of twelve votes. The court of appeals agreed, held that the error was harmful, and reversed. The Supreme Court reversed, holding that the trial court's failure to submit the requested 10-2 instruction did not probably cause the rendition of an improper judgment, and therefore, the trial court's legal error was harmless. View "In re Commitment of Gregory Jones" on Justia Law