Alfred E. Brown, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals affirmed the Court of Appeals' reversal of the trial court's conviction, holding that when the evidence raises a genuine issue that the defendant's conduct was not voluntary, the jury must be instructed on voluntariness. The State's argument that voluntariness is subsumed by the intentional or knowing element was rejected. The majority declined to adopt a bright‑line rule, emphasizing case‑by‑case analysis.