Court of Criminal Appeals of Texas

Robert Lee Menefee, Appellant v. the State of Texas

July 1, 20092009 Tex. Crim. App. LEXIS 881

Summary

The Court held that a defendant’s sworn acknowledgment of pleading guilty does not satisfy Article 1.15’s requirement that a guilty plea be supported by independent evidence, reversing the Court of Appeals and remanding for further consideration. Justice Keller dissented, arguing the appeal certification was defective and the petition should be dismissed, while Justices Womack and Cochran filed concurring opinions agreeing with the majority’s holding but offering historical and procedural commentary.