Court of Criminal Appeals of Texas

Thomas Carl Johnson & Robert Darnell Stapp, Appellants v. the State of Texas, Appellee

November 16, 19881988 Tex. Crim. App. LEXIS 247

Summary

The Court of Criminal Appeals of Texas affirmed the convictions of Johnson and Stapp, holding that the trial court’s admonitions were sufficient and that the appellants knowingly and intelligently waived their Sixth Amendment right to counsel while proceeding pro se. The majority reasoned that the record showed the defendants understood the risks of self‑representation. A dissent argued the admonitions were inadequate and the waiver was not properly established, and a partial concurrence agreed with the result but criticized the reliance on the Martin decision’s interpretation of Faretta.