Court of Criminal Appeals of Texas
Keith Lashone Hogans, Appellant v. the State of Texas
November 9, 20052005 Tex. Crim. App. LEXIS 1960
Summary
The Court affirmed the Court of Appeals' dismissal of appellant's ineffective assistance claim, holding that the claim related to the trial court's adjudication of guilt and therefore fell outside appellate jurisdiction. The Court clarified that appellate courts may consider pre‑adjudication claims only when they directly and distinctly relate to punishment. Separate dissenting opinions argued for a broader “relief‑sought” approach, but the majority maintained the statutory limitation.