Ex Parte Judy Cox Swate, Relator

Summary

The Texas Supreme Court granted Judy Cox Swate's petition for a writ of habeas corpus, holding that the trial court's commitment order was void because it enhanced her punishment without notice or an opportunity to be heard, violating due process. The Court relied on Ex parte Parr and related precedent to conclude that post‑contempt enhancements require a new notice and hearing. Justice Gonzalez filed a concurring opinion asserting that the trial court also lacked authority to issue the turnover order, but this reasoning did not affect the majority holding.