Michael Scott, Appellant v. the State of Texas

Summary

The Texas Court of Criminal Appeals held that the trial court erred in admitting the co‑defendant’s out‑of‑court statement in violation of the Sixth Amendment Confrontation Clause and that the error was not harmless beyond a reasonable doubt, reversing the capital murder conviction and remanding for a new trial. The Court applied a four‑factor harmless‑error analysis and concluded the admission could have influenced the jury. Justice Keller, dissenting, argued the interrogation was non‑coercive, the admission was harmless, and the conviction should have been affirmed.