Court of Criminal Appeals of Texas

Jose Ricardo Castillo, Appellant v. the State of Texas, Appellee

November 29, 19951995 Tex. Crim. App. LEXIS 124

Summary

The Court held that Garrett v. State overrules Caldwell v. State, so a venireman who refuses to convict on the basis of a single eyewitness is not challengeable for cause when the refusal stems from a higher reasonable‑doubt threshold; it vacated the Court of Appeals judgment and remanded for further application of that standard. Separate dissents (Mansfield and Keller) argue Caldwell remains controlling and would affirm the judgment, while a concurrence (Baird) agrees Garrett controls but says the cases can be reconciled.