Court of Criminal Appeals of Texas
Saul Contreras, Appellant v. the State of Texas
June 9, 20102010 Tex. Crim. App. LEXIS 687
Summary
The Court reversed the Court of Appeals and remanded for a harm analysis, holding that the threat to arrest the appellant's wife created a factual dispute requiring a Article 38.23 due‑process instruction, that lack of sleep, brief isolation, and invocation of counsel did not independently require such an instruction, and that moral and conceptual equivalence of underlying felonies is not required for unanimity in a felony‑murder case.