Harold Wayne Bailey, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that the appellant's notice of appeal was timely because the sentence was not complete until the restitution order was entered on March 12, 2001, and therefore reversed the lower court's dismissal and remanded for a merits hearing. The majority clarified that restitution is part of the sentencing process, making the filing deadline start when the restitution order is entered. Three separate opinions dissented, arguing that the decision would open the floodgates to appeals of post‑sentencing probation modifications.