Humberto Almazo Hoyos, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals affirmed Humberto Almazo Hoyos's conviction, holding that the trial court properly excluded the appellant's proposed testimony about the complainant's anticipated civil lawsuit because the record showed no relevance to the complainant's bias. The Court reasoned that none of the four factors—party status, relationship, contested crime, or other bias—were present and that the record at the time of the ruling controls the validity of the exclusion. A dissent argued that the civil suit and the complainant's deferred adjudication status were relevant to bias and should have been admitted.