Court of Criminal Appeals of Texas

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

November 24, 19931993 Tex. Crim. App. LEXIS 187

Summary

The Court affirmed the Court of Appeals, holding that the trial court's charge correctly placed the burden on the defendant to prove duress and did not violate Fourteenth Amendment due process because the term “voluntarily” in Tex. Penal Code §6.01(a) refers only to the absence of an accidental act, i.e., physical bodily movements, not a mental free‑will element. A concurrence agreed with the judgment but criticized the majority's definition of “voluntarily.”