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 held that the trial court must have given a Article 38.23 instruction concerning the threat to arrest the appellant’s wife because a factual dispute existed, and it rejected the appellant’s claim that the felony‑murder jury charge violated his right to a unanimous verdict; moral and conceptual equivalence of the underlying felonies is not required. The judgment of the Court of Appeals was reversed and the case remanded for a harm analysis. Justice WOMACK, concurring, noted the discussion of Miranda was moot.