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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision

State v. Hart

Doyle Hart was convicted of aggravated rape and incest. His stepdaughter, B.J., later recanted her trial testimony, leading Hart to file a petition for writ of error coram nobis for a new trial based on this newly discovered evidence. The trial court denied the petition, citing B.J.'s reassertion of her original testimony while in a mental health facility and the results of an unfavorable polygraph examination taken by Hart. The Court of Criminal Appeals reversed and remanded the case for a new evidentiary hearing. The appellate court found that the trial court improperly considered evidence outside the record, specifically B.J.'s post-hearing statements and the polygraph results, violating principles of judicial procedure and evidence.

Aggravated RapeIncestRecanted TestimonyWrit of Error Coram NobisNewly Discovered EvidenceJudicial MisconductEvidence Outside RecordPolygraph ExaminationCredibility AssessmentChild Abuse
References
33
Case No. WR No. 20,644
Regular Panel Decision
Feb 25, 2015

Larson, Paul Allen

Paul Larson, acting pro se, filed a Petition for Writ of Error/Bill of Review with the Texas Court of Criminal Appeals. Larson alleges errors appearing on the face of the record and extrinsic fraud committed by the State in connection with prior Cause Numbers 449008-C, 449008-D, 465007-C, and 465007-D. He specifically claims the State mislabeled a June 12, 2014, answer as 'Original' and intentionally delayed its delivery. Larson seeks a full review of the Habeas Record, an order for the Harris County District Clerk's Office to provide complete files, and for the Court to grant his Bill of Review and the relief originally sought in his Applications for Writ of Habeas Corpus and/or Writ of Mandamus.

Writ of ErrorBill of ReviewHabeas CorpusMandamusFraudError on RecordExtrinsic FraudTexas Court of Criminal AppealsPro SeSupervised Release
References
2
Case No. MISSING
Regular Panel Decision

People v. Clayton

This document presents a dissenting opinion regarding the denial of a defendant's coram nobis application. The defendant, an illiterate 24-year-old farm hand, was convicted of murder in the second degree based on a written confession. The dissent argues that the confession was improperly obtained and its admission constituted reversible error. The defendant was detained for approximately 60 hours, questioned repeatedly without being advised of his rights, and allegedly denied access to an attorney and contact with his mother. Furthermore, his detention as a material witness was deemed illegal since no criminal action was pending at the time. The dissenting judge concluded that the defendant's will was overborne by constant police pressure, rendering the confession involuntary and inadmissible.

Coram NobisInvoluntary ConfessionIllegal DetentionMiranda RightsDue ProcessCriminal ProcedureAppellate ReviewSecond-Degree MurderPolice CoercionMaterial Witness
References
6
Case No. M2005-02959-CCA-R3-PD
Regular Panel Decision
Jul 07, 2008

Derrick Quintero and William Eugene Hall, Jr. v. State of Tennessee

The appellants, Derrick Quintero and William Eugene Hall, Jr., appealed the denial of their pro se post-conviction petitions and joint petitions for writ of error coram nobis. They were originally convicted of multiple counts of murder and burglary, receiving the death penalty for one murder and a life sentence for another. The petitions alleged constitutional violations including ineffective assistance of counsel and newly discovered evidence from fellow inmates claiming another escapee, Blanton, confessed to acting alone in the murders. The trial court denied relief, finding the new evidence lacked veracity and the claims of ineffective assistance of counsel unsubstantiated or harmless. The Court of Criminal Appeals of Tennessee affirmed the judgments, finding no abuse of discretion in denying coram nobis relief and no sufficient proof of ineffective assistance of counsel.

Criminal AppealsPost-Conviction ReliefDeath PenaltyMurderBurglaryLarcenyIneffective Assistance of CounselAlibi DefenseNewly Discovered EvidenceWrit of Error Coram Nobis
References
66
Case No. MISSING
Regular Panel Decision

Total Oilfield Services, Inc. v. Garcia

Jose Alejo Garcia, a Texas resident, was killed in an industrial accident in Oklahoma while working for Total Oilfield Services, a Texas corporation. His survivors received worker's compensation benefits under Oklahoma law and subsequently sued in Texas for exemplary damages under the Texas Wrongful Death Act. The trial court dismissed the action due to Oklahoma's exclusive remedy, but the court of appeals reversed, asserting the extra-territorial effect of the Texas Wrongful Death Act. This court refused the application for writ of error, finding no reversible error in the outcome. However, it disapproved the court of appeals' reasoning that the 'most significant relationship' rule was inapplicable, clarifying that said rule should be applied in such conflict of laws cases.

Wrongful Death ActConflict of LawsMost Significant Relationship TestWorker's CompensationExtra-territorial EffectWrit of ErrorExemplary DamagesSubject Matter JurisdictionStatutory InterpretationPer Curiam
References
3
Case No. No. 09-274, No. 11-CR-230, No. E2011-00500-CCA-R3-CD, No. E2011-02114-CCA-R3-PC
Regular Panel Decision
Dec 21, 2012

State of Tennessee v. Thomas D. Taylor

This case consolidates two appeals by Thomas D. Taylor: a direct appeal and an appeal from the denial of a petition for a writ of error coram nobis. Taylor was convicted of especially aggravated kidnapping and aggravated assault, receiving a seventy-year sentence. He alleged ineffective assistance of counsel, trial court error in limiting cross-examination, prosecutorial misconduct, and failure to consider newly discovered evidence (victim's medical records indicating delusions). The Court of Criminal Appeals affirmed the judgments, finding no prejudice from counsel's performance and ruling that the 'newly discovered evidence' lacked diligence in discovery and was not credible.

Criminal AppealEspecially Aggravated KidnappingAggravated AssaultIneffective Assistance of CounselProsecutorial MisconductCross-Examination LimitsNewly Discovered EvidenceWrit of Error Coram NobisAppellate ReviewVictim Credibility
References
55
Case No. MISSING
Regular Panel Decision

Dean v. United States

The government sought reconsideration of the grant of Kevin Dean's coram nobis petition, arguing preclusion and requesting discovery on three elements for coram nobis relief. The court rejected the government's preclusion argument as waived and without merit. It denied discovery on 'continuing legal consequences' and 'compelling reasons,' finding Dean's job termination a clear civil consequence and actual innocence not a prerequisite for the writ. However, the court granted the government's request for discovery on the element of 'undue delay,' allowing inquiry into Dean's awareness of the conviction's collateral civil consequences prior to his termination.

Coram NobisReconsideration MotionExpungement of RecordDue ProcessGuilty PleaCollateral EstoppelRes JudicataCriminal Record AccuracyPublic LewdnessCivil Consequences
References
21
Case No. No. 115
Regular Panel Decision
Nov 20, 2017

The People v. Mario Arjune

The case concerns Mario Arjune's writ of error coram nobis, alleging ineffective assistance of counsel. Arjune, an immigrant with cognitive limitations, was convicted of tampering with evidence and weapon possession. His trial counsel filed a notice of appeal but took no further action, leading to its dismissal. Arjune claimed he was unaware of his appellate rights and entitlement to poor person relief. The Court of Appeals affirmed the denial, finding Arjune failed to demonstrate ineffective assistance or due diligence, and declined to broaden exceptions to appeal deadlines.

Ineffective Assistance of CounselRight to AppealCoram NobisAppellate ProcedurePoor Person ReliefCognitive LimitationsDeportation ConsequencesTrial Counsel DutiesNotice of AppealDue Diligence
References
20
Case No. No. 13
Regular Panel Decision
Mar 28, 2019

The People v. Omar Alvarez

Omar Alvarez appealed the denial of his writ of error coram nobis, alleging ineffective assistance of appellate counsel. He claimed his original appellate counsel failed to challenge his 66 ⅔ years to life sentence as unduly harsh, submitted a deficient brief, and communicated poorly. The New York Court of Appeals affirmed, ruling that counsel provided meaningful representation, highlighting the discretion afforded to appellate attorneys in selecting arguments. The court found no strategic reason for counsel to pursue an excessive sentence claim given the violent crimes and Alvarez's conduct. Dissenting opinions, however, criticized counsel's overall performance, particularly the brief's quality and the missed opportunity to argue for a sentence reduction, especially considering the defendant's youth at the time of the offense.

Ineffective Assistance of CounselAppellate CounselCoram NobisSentence ReviewUnduly Harsh SentenceMeaningful RepresentationCriminal Procedure LawCourt of AppealsNarcotics TraffickingHomicide Conviction
References
50
Case No. MISSING
Regular Panel Decision

Texaco, Inc. v. Central Power & Light Co.

Texaco appealed to the Supreme Court of Texas by writ of error after the court of appeals dismissed its appeal, ruling Texaco had participated sufficiently in the trial to be barred from this method of appeal. In the initial trial, Texaco had settled with the plaintiffs, Eduardo and Hilda Jean Espinoza, but was later found liable for indemnity to Central Power and Light Company (CP&L) based on a tariff. The Supreme Court reversed the court of appeals' judgment, clarifying that 'actual trial' participation, specifically involvement in the evidentiary stage or 'decision-making event' that adjudicates rights, is required to preclude a writ of error appeal. Since Texaco did not participate in the jury trial that established CP&L's liability to the Espinozas or the subsequent indemnity judgment against Texaco, the Supreme Court held Texaco was entitled to appeal by writ of error. The case was remanded for consideration of Texaco’s points of error.

Writ of ErrorAppellate ProcedureTexas Rules of Appellate ProcedureActual Trial ParticipationIndemnity ClaimSettlement AgreementJudicial NoticeNonparticipation RuleJury TrialSupreme Court of Texas
References
18
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