Michael Dennis Quinn, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals reversed the Court of Appeals and held that no new trial was warranted on either the unauthorized juror communication or alleged juror bias, affirming the conviction. The Court emphasized deference to the trial court's credibility findings and rejected the notion that out‑of‑court statements automatically establish bias. Justice Baird dissented to the decision to publish the opinion, arguing it adds no jurisprudential value.