Court of Criminal Appeals of Texas
Nelrie Byrd Carroll, Appellant v. the State of Texas
September 16, 19981998 Tex. Crim. App. LEXIS 110
Summary
The Court held that a guilty plea creates a unitary trial, so the defendant's written waiver of the Fifth Amendment privilege against self‑incrimination applies to the entire adjudication, including sentencing, and reversed and remanded the lower appellate court. Justice Meyers dissented, arguing the waiver does not extend to the punishment phase and may be withdrawn.