Nelrie Byrd Carroll, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals reversed the lower courts and remanded, holding that a guilty plea in a non‑capital felony case creates a unitary trial and that the defendant's written waiver of her Fifth Amendment privilege applies to the entire proceeding, including sentencing. The majority distinguished prior cases involving not‑guilty pleas and emphasized the effect of the written waiver. Justice Meyers dissented, arguing that the waiver could be withdrawn and that the trial was improperly coerced.