Court of Criminal Appeals of Texas

Jerry Robert Davidson, Appellant v. the State of Texas

May 24, 20002000 Tex. Crim. App. LEXIS 59

Summary

The Court held that oral statements obtained from the appellant in Montana, which were not electronically recorded, are inadmissible under Texas Code of Criminal Procedure Article 38.22. Accordingly, the Court reversed the Court of Appeals' decision and remanded for a harm analysis. The majority also concluded that the Full Faith and Credit Clause does not require Texas to admit the statements despite the non‑compliance with Article 38.22.