Anthony Dixon, Appellant v. the State of Texas

Summary

The Court held that a trial court’s refusal to require the State to elect a specific offense must be analyzed under the constitutional‑error harm standard, and under the facts the error was harmless, so it reversed the Court of Appeals and remanded for further proceedings. The Court reasoned that the victim’s testimony described a single pattern of conduct without distinct incidents, eliminating any risk to notice, unanimity, or extraneous‑offense concerns. Justice Price dissented, arguing the error was harmless, while Justice Cochran concurred, urging legislative reform of Texas election law.