Court of Criminal Appeals of Texas
Peek v. State
May 21, 2003106 S.W.3d 72
Summary
The Court held that under Article 36.02 a trial court must reopen a case only when the proffered evidence would materially change the case in the proponent’s favor, overruling the broader relevance test adopted in Vital. It affirmed the Court of Appeals’ judgment that the Baytown medical records would not have materially changed the outcome.