Ray Gonzalez, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas affirmed the lower court, holding that Ray Gonzalez forfeited his Sixth Amendment confrontation right by killing Maria Herrera, so her out‑of‑court statements were admissible. The court applied the forfeiture‑by‑wrongdoing doctrine without requiring proof that Gonzalez intended to silence the witness, and it declined to resolve whether the statements were dying declarations or testimonial. Justice Johnson filed a concurring opinion, agreeing with the judgment but cautioning against expanding the forfeiture doctrine.