Court of Criminal Appeals of Texas

Christopher Irby, Appellant v. the State of Texas

June 16, 20102010 Tex. Crim. App. LEXIS 725

Summary

The Court affirmed the conviction, holding that the trial judge did not err in refusing to allow cross‑examination of the juvenile victim about his deferred‑adjudication probation because the appellant failed to show a causal connection between that status and any bias. The majority interpreted Davis v. Alaska as requiring a logical link, not a blanket rule, and overruled the broader reading of Maxwell. Justice Holcomb dissented, arguing that the majority misapplies Davis and improperly restricts the defendant’s confrontation rights.