Court of Criminal Appeals of Texas
Michael Dennis Quinn, Appellant v. the State of Texas
December 3, 19971997 Tex. Crim. App. LEXIS 103
Summary
The Texas Court of Criminal Appeals reversed the Court of Appeals' decision granting Michael Quinn a new trial based on alleged juror misconduct and bias, holding that the trial court's factual findings and credibility determinations were entitled to deference. The court found no prejudice from the unauthorized conversation and no actionable bias, and remanded for consideration of the remaining issues. Justice Baird dissented, arguing the opinion should not be published.