Robert Lee Menefee, Appellant v. the State of Texas

Summary

The Court held that a defendant’s sworn affirmation of pleading guilty, without affirming the truth of the indictment’s elements, does not satisfy Article 1.15’s requirement of independent evidence to support a guilty plea, rendering the conviction error and requiring vacatur and remand. The decision relied on the Court’s prior rulings that such colloquy is not a judicial confession and disapproved contrary authority. The Court also instructed the Court of Appeals to address unresolved issues, including evidentiary support, procedural default, and harmless error analysis. The opinion was accompanied by a dissent challenging jurisdiction and two concurrences supporting the majority’s reasoning.