Arsenio Carlos Clarke, Appellant v. the State of Texas

Summary

The Court held that a claim that a trial court erred in denying a motion for new trial is preserved for appellate review when the nature of the ground is raised and litigated, without objection, during the motion‑for‑new‑trial proceedings, and affirmed that appellant’s Brady/Giglio complaint was sufficiently specific to preserve error. Justice Keller dissented, arguing that the oral amendment violated Rule 21.4’s filing requirements.