Randall Wayne Hafdahl, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas affirmed Randall Wayne Hafdahl’s capital murder conviction and death sentence. It rejected all six of appellant’s asserted errors, holding that the evidence of a prior kidnapping investigation was admissible, that there was no Brady violation, that no hearing was required on the new‑trial motion, that the appellant waived his right to an instructed verdict, that the officer was acting in the lawful discharge of duty, and that the appellant’s out‑of‑court statement was properly excluded. The majority relied on prior Texas precedent and federal due‑process standards. A dissent argued that the admission of the extraneous kidnapping evidence was error not harmless and should reverse the judgment.