Court of Criminal Appeals of Texas
Montgomery, Beecher v. the State of Texas
July 2, 2026
Summary
The Court held that the Sixth Amendment's Confrontation Clause does not apply to a hearing on a motion to enter adjudication of guilt and revoke deferred-adjudication community supervision. Because the proceeding is not a criminal prosecution under the Clause, conducting it virtually over the appellant's objection did not violate his confrontation right, and the Court affirmed the court of appeals. Judge Finley, dissenting, would have treated the adjudication hearing as a continuation of the unresolved criminal prosecution, while Judge Walker, dissenting, criticized the Court for failing to squarely address deferred adjudication; Judges Keel and Parker, concurring, offered additional grounds for affirmance.