Phyllis Anne Woodall, Appellant v. the State of Texas

Summary

The Court of Criminal Appeals of Texas reversed the lower appellate court, holding that a witness's memory loss does not make her "absent" for Confrontation Clause purposes and that the appellant is estopped from raising a Confrontation Clause claim because she declined the trial court's offer to secure the witness's presence. The decision was accompanied by two concurring opinions that agreed with the reversal but differed on the application of estoppel.