Court of Criminal Appeals of Texas

Jorge Salinas Carrillo v. the State of Texas

September 15, 19991999 Tex. Crim. App. LEXIS 95

Summary

The Texas Court of Criminal Appeals held that failure to comply with Article 21.25's substitution requirements does not divest a trial court of jurisdiction once an indictment has been presented. The court overruled the long‑standing rule that a proper substitution is a jurisdictional fact, reversed the Court of Appeals, and remanded for further consideration.