Williams, Jemadari Chinua v. the State of Texas

Summary

The Court held that the court of appeals properly considered Appellant’s preserved but unassigned indictment-notice claim on remand, because the prior remand did not resolve that distinct claim and the court of appeals retained broad authority to address remaining issues. The Court assumed without deciding that the indictment was defective, but held that any defect was harmless because the record showed Appellant knew the State’s theories and evidence before trial and pursued a defense unrelated to uncertainty about the statutory methods. The judgment of the court of appeals was reversed and the case was remanded. Judge Parker, joined by Judge Keel, concurred in the result but would also have rejected the notice claim on grounds that the statutory terms were sufficiently specific, the alleged overlap was legally inconsequential, and the methods constituted one offense.