Orlando Vargas, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas reversed the Court of Appeals' judgment and remanded for reconsideration of appellant Vargas's Batson claim, holding that the appellate court may not rely on comparative evidence that was not part of the trial record. The Court affirmed that the trial judge's finding that the prosecutor's peremptory challenges were race‑neutral was supported by the record and not clearly erroneous. The decision applied a clear‑error standard of review to the Batson issue and required the lower court to evaluate the claim consistent with that standard.