Court of Criminal Appeals of Texas

Samuel Lovert Johnson, Appellant v. the State of Texas

October 7, 19981998 Tex. Crim. App. LEXIS 131

Summary

The Court held that prospective jurors who cannot consider the minimum legal punishment for a defendant found guilty as a principal are biased under Article 35.16(c)(2) and therefore challengeable for cause; it vacated the Court of Appeals' judgment and remanded for a harm analysis. Separate opinions dissent on the proper approach to juror bias and the application of Garrett.