Court of Criminal Appeals of Texas
The State of Texas, Appellant v. Patricia Ann Hall, Appellee
March 25, 19921992 Tex. Crim. App. LEXIS 64
Summary
The Court of Criminal Appeals affirmed the lower court's dismissal of the information against Patricia Ann Hall, holding that the district court that originally received the indictments lacked competent jurisdiction because the indictments did not allege misdemeanors involving official misconduct, and therefore the two‑year statute of limitations was not tolled. The Court relied on the statutory definition of "official misconduct" and prior precedent interpreting that term. A concurring opinion agreed with the result but discussed the legislative history of "official misconduct". Justice Clinton, in a separate concurrence, offered additional commentary on the evolution of the term.