Court of Criminal Appeals of Texas
Clifton Edmond Green, Appellant v. the State of Texas, Appellee
January 12, 19941994 Tex. Crim. App. LEXIS 8
Summary
The Court of Criminal Appeals affirmed the conviction, holding that the preliminary initial appearance (PIA) was not a critical stage invoking the Sixth Amendment right to counsel, and therefore the appellant neither had a right to counsel at that hearing nor waived any such right. The Court also found the error harmless. Separate opinions dissent and concur on the critical‑stage analysis.