Howard Leroy Woodfox, Appellant v. the State of Texas, Appellee

Summary

The Texas Court of Criminal Appeals held that a non‑testifying defendant may raise a mistake‑of‑fact defense and is entitled to a jury instruction when the evidence, even if limited to the defendant’s out‑of‑court statements reported by police, raises the issue. The court overruled the prior holdings in Williams and Harper that required the defendant’s testimony, and remanded the case for the Court of Appeals to apply this rule. A dissent argued that the majority improperly overruled Williams and Harper and that the trial court correctly denied the instruction.