Court of Criminal Appeals of Texas
Teddy Joe McDonald, Appellant v. the State of Texas, Appellee
November 26, 19801980 Tex. Crim. App. LEXIS 1468
Summary
The Court held that a trial court that takes judicial notice of testimony from a prior trial in a probation revocation hearing must make specific findings on whether it accepted or rejected that testimony and on the witness's credibility; because the trial court failed to do so, the revocation order was set aside and the case remanded. A dissent argued that no error required reversal, while a concurrence agreed with reversal but on different grounds.