Court of Criminal Appeals of Texas
Johnny Gonzales, Appellant v. the State of Texas
September 15, 19991999 Tex. Crim. App. LEXIS 100
Summary
The Court of Criminal Appeals affirmed the Court of Appeals' judgment, holding that a juror's failure to disclose on a written questionnaire that she was a complainant does not constitute juror misconduct warranting reversal when the parties did not ask direct questions at voir dire. The Court emphasized that defense counsel must diligently inquire about potential bias, and that written questionnaires alone are insufficient for discovering material information.