Christopher J. Alford, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals affirmed the lower court's judgment, holding that the trial court's charge placing the burden on the defendant to prove duress did not violate Fourteenth Amendment due process because the term "voluntarily" in Texas Penal Code §6.01(a) refers only to the physical act and not to a mental free‑will element. The Court also defined "voluntarily" as the absence of an accidental act, limiting the State's burden to prove voluntariness only when an accident issue is raised. Justice Clinton concurred in the judgment but criticized the majority's definition of "voluntarily".