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.