Lonnie Ray Barfield, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that in a bench trial without a jury, evidence introduced at the punishment stage may be considered when assessing the sufficiency of the evidence of guilt, and therefore affirmed the district court's conviction despite the trial's improper bifurcation. Justice Johnson dissented, arguing the Court lacked jurisdiction and that the statutory bifurcation rule applies only to jury trials.