Court of Criminal Appeals of Texas
The State of Texas v. Mark Twain Simpson, Appellee
April 27, 20162016 Tex. Crim. App. LEXIS 74
Summary
The Texas Court of Criminal Appeals affirmed the Dallas Court of Appeals' reversal of the trial court's grant of a new trial on the ground that the defendant's Eighth Amendment gross disproportionality claim was not substantiated by the record. The court held that the proper standard of review for such a grant is abuse of discretion and that the trial court abused that discretion by acting without guiding principles.