Jose Fidel Guajardo, Appellant v. the State of Texas

Summary

The Court reversed the Court of Appeals and affirmed the trial court, holding that the appellant failed to provide a sufficient record of the prior suppression hearing and therefore could not obtain appellate review of his collateral estoppel claim. The decision notes that without the complete record a reviewing court cannot determine the factual issue previously decided, and it declines to address broader questions about collateral estoppel beyond the double jeopardy context. Justice Hervey, in a concurring opinion, argued that the record was unnecessary and that collateral estoppel should not apply beyond double jeopardy; Justice Meyers concurred on the result, emphasizing conflict with other appellate decisions; Justice Johnson concurred, noting the appellant did not preserve any error regarding the seizure of the drugs.