Arthur Garcia Sanchez, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that the appropriate test for determining harmless error when the State improperly commits jurors is the standard set out in Rule 44.2(b) of the Texas Rules of Appellate Procedure, applying a tailored set of factors to assess whether the defendant's substantial rights were affected. It found the Court of Appeals erred by relying on the Anson test and therefore vacated the judgment and remanded for further proceedings under the proper standard. A concurring opinion noted disagreement with the discussion of voir dire purposes.