B.j. Franklin, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals affirmed the Court of Appeals' judgment that the trial judge erred in denying a mistrial when a juror disclosed a relationship with the victim, and that the error is of constitutional dimension requiring a Rule 44.2(a) harmless‑error review. The majority held that the proper standard of harm is the constitutional standard, while two dissenting opinions argued for a different standard and for remand under federal bias‑bias analysis.