Juan Antonio Carranza, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals affirmed the Court of Appeals' reversal, holding that the trial court's failure to substantially comply with Article 26.13(a)(4) by not admonishing the defendant about possible deportation was a reversible error that affected a substantial right. The error was deemed non‑constitutional, and the Court declined to apply a harmless‑error analysis under Rule 44.2(b). The dissent and a concurring opinion argued that the majority erred in applying a harm analysis where the statute provides its own distinction between compliance and non‑compliance.