Billy Don Craig, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas held that the Court of Appeals erred by applying the Strickland test to evaluate ineffective assistance of counsel during the punishment phase of a non‑capital murder trial and remanded for reconsideration using the Ex parte Duffy standard; Justice Benavides dissented, arguing the record was insufficient for such a determination on direct appeal.