Robert Daniel Maxwell, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals held that a defendant may impeach a State witness by introducing evidence of the witness's deferred adjudication probation status to show bias, motive, or interest, thereby overruling Jones. The Court reversed the Court of Appeals' judgment and remanded for a harm analysis. Justice Keller, in dissent, argued that Jones should not be overruled and that the majority misapplied prior case law. The dissent also contended that the witness's subsequent conviction should not affect the analysis.