The State of Texas v. Carolyn Sue Krizan-Wilson, Appellee

Summary

The Texas Court of Criminal Appeals affirmed the appellate court's reversal of the trial court's dismissal of a murder indictment, holding that the defendant must prove both substantial prejudice and an intentional, bad‑faith purpose for the pre‑indictment delay, that the correct standard of review for the trial court's mixed factual‑legal finding is abuse of discretion, and that a 23‑year delay without proof of bad faith does not violate the Fifth Amendment due‑process clause.