Ex Parte Bernard Eugene Crisp, Jerry Michael Miles, Joe Lee Sewell. ex Parte Bruce Dudley Carter

Summary

The Court of Criminal Appeals held that the caption of House Bill 730 failed to give fair notice under Texas Constitution Article III, §35, rendering the amendment unconstitutional; consequently the original Controlled Substances Act remained in force and the indictment based on the pre‑amendment law was affirmed. The Court affirmed the lower appellate judgment. A dissent argued for a broader "notice to prevent surprise or fraud" standard and would have upheld the statute, while a concurrence agreed with the result but emphasized that the phrase "relating to" is insufficient under the first sentence of the constitutional provision.