Court of Criminal Appeals of Texas

Jose Medrano Garcia, Appellant v. the State of Texas

March 24, 20042004 Tex. Crim. App. LEXIS 519

Summary

The Court held that Garcia's conviction violated the Sixth Amendment Confrontation Clause because he was tried without a competent interpreter despite the trial judge's awareness of his language deficiency and without a knowing and intelligent waiver. The Court reversed the Court of Appeals and remanded for a determination of harmless error. Justice Keller, concurring, agreed with the majority and emphasized the interpreter right as a non‑waivable category‑two right.