Sandra Cheney, Appellant v. the State of Texas, Appellee

Summary

The Court held that Texas Penal Code sections 31.03 (theft) and 32.32 (false statement to obtain property or credit) are not in pari materia, so the special‑general statutory analysis does not apply and the conviction under section 31.03 is proper. Accordingly, the Court reversed the Court of Appeals' decision and remanded for further adjudication of the remaining issues. Justice Clinton filed a concurring opinion agreeing with the majority and offering additional commentary on the statutory analysis.