Bruce Edwin Callins, Appellant v. the State of Texas, Appellee

Summary

The Court upheld the capital murder conviction on the sufficiency of evidence for deliberateness, but reversed the conviction for capital murder on the ground that the trial court failed to require an election to cure the misjoinder of non‑property offenses, and remanded for further proceedings. The decision rests on the application of Article 21.24 of the Texas Code of Criminal Procedure and the distinction between property and non‑property offenses. A dissent and two concurrences were filed, the former contesting the majority's reversal and the latter proposing alternative rules for handling multiple convictions.