Wilkie Schell Colyer, Jr., Appellant v. the State of Texas

Summary

The Court of Criminal Appeals held that the trial judge did not abuse his discretion in denying a motion for new trial based on juror testimony alleging outside influences, and clarified that personal pressures such as weather concerns or a doctor's call are not "outside influences" under Texas Rule of Evidence 606(b). Accordingly, the appellate court reversed the Court of Appeals decision and affirmed the trial judge's ruling.