Wilbert Campbell, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that the terms "felony" and "state jail felony" are mutually exclusive in Texas Penal Code §12.42(a), so a defendant with prior state jail felony convictions is punished as a third-degree felony under §12.42(a)(1) rather than a second-degree felony under §12.42(a)(2). The decision reverses the lower court's sentencing enhancement and remands for a new punishment hearing. A dissent argued that "felonies" includes state jail felonies and that the majority's interpretation creates an absurd result.