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 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 misconduct requiring reversal because defense counsel did not ask follow‑up oral questions. The Court noted that counsel has a duty to be diligent in eliciting material information, and written questionnaires alone are insufficient for that purpose. Justice McCormick, in a concurring opinion, agreed with the judgment but argued the petition was improvidently granted.