Thurman Victor Cunningham, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas affirmed the Court of Appeals' decision that the trial court did not abuse its discretion in excluding the out-of-court statements under Texas Rule 803(24). It held that appellate review of such exclusions is limited to an abuse-of-discretion standard and that the proper test for corroboration is a flexible, factor‑based inquiry rather than a rigid formula.