Court of Criminal Appeals of Texas
Ex Parte Stephen Craig Thompson, Applicant
January 12, 20052005 Tex. Crim. App. LEXIS 4
Summary
The Court held that the applicant met the extraordinary burden of proving, by clear and convincing evidence, that no reasonable juror would convict him in light of newly discovered evidence, and therefore granted habeas relief, setting aside his conviction and remanding the case for the state to answer the charges. The decision rests on the Elizondo standard that actual innocence claims require the applicant to show that the new evidence unquestionably establishes innocence when weighed against the trial evidence. The Court also clarified its de novo review of the legal question of whether the new evidence meets the "unquestionably innocent" threshold while deferring to the trial court's factual findings. The opinion was accompanied by a concurring opinion that elaborated the conceptual framework for evaluating actual innocence claims and a dissenting opinion that argued the Court’s evolving jurisprudence departs from Elizondo and Herrera.