Jose Medrano Garcia, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that Jose Medrano Garcia's Sixth Amendment Confrontation Clause right was violated because he was tried without a competent interpreter despite the trial judge's awareness of his inability to understand English and his lack of a knowing, intelligent waiver. The Court classified the right to an interpreter as a category‑two Marin right that must be provided unless expressly waived. Accordingly, the Court reversed the Court of Appeals' judgment and remanded for a determination of prejudice. Justice Keller, in a concurring opinion, agreed with the result but proposed a different procedural framework for when the trial court must inquire about a defendant's language needs.