Court of Criminal Appeals of Texas
Carlos Ruedas, Appellant v. the State of Texas, Appellee
September 19, 19791979 Tex. Crim. App. LEXIS 1627
Summary
The Court reversed both the burglary conviction and the probation revocation because the trial court improperly denied the appellant the opportunity to make a closing argument in both the criminal trial and the probation revocation hearing. The Court held that the constitutional right to counsel includes the right to be heard in argument at the close of testimony in criminal prosecutions and that this right likewise extends to all phases of a probation revocation proceeding.