Jerry Robert Davidson, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas held that Texas Code of Criminal Procedure Article 38.22, §3(a) requires strict compliance with its electronic recording requirement, rendering the appellant's out‑of‑state custodial statements inadmissible. Accordingly, the Court reversed the Court of Appeals and remanded for a harm analysis. Two dissenting opinions argued that the statute should not apply to statements obtained by non‑Texas officers outside Texas and would have held the statements admissible.