Allen Wayne Janecka, Appellant v. the State of Texas, Appellee

Summary

The Court affirmed the capital murder conviction but remanded for a hearing to determine whether the indictment’s failure to name the remunerating party caused prejudice, overturning the trial court’s denial of the motion to quash. It overruled the Brasfield analysis, reaffirmed American Plant Food and Adams holdings on notice defects, and rejected the State’s arguments on the date of remuneration, the arson warrant’s probable cause, and the admissibility of confessions. Separate dissenting opinions criticize the reliance on Adams and the Gates test.