Ex Parte Jimmy Dean Watkins

Summary

The Court held that collateral estoppel bars the State from relitigating the issue of sudden passion in a subsequent prosecution, because a jury found that fact at the punishment phase of the first trial. The State may still prosecute for attempted murder, but may not contest the sudden‑passion finding. The Court affirmed the Court of Appeals and remanded for further proceedings. Justice Keller, dissenting, argued that the claim is not cognizable on a pre‑trial habeas petition and would have vacated and dismissed the application.