Wilbert James Teal, Appellant v. the State of Texas

Summary

The Court held that the indictment, even though it omitted an allegation that Teal knew the fugitive’s felony status, nonetheless vested the district court with subject‑matter jurisdiction under Studer, and that Teal’s failure to object to this alleged defect before trial waived any appellate review. Accordingly, the Court vacated the Court of Appeals’ judgment and remanded for consideration of Teal’s remaining claims. Justice Keller, in a concurring opinion, agreed with the judgment but argued that the proper analysis is a step‑2 inquiry into indictment defectiveness.