in-camera hearing in Texas

20 Texas opinions name it 2 courts 1985–2024 5 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

Case	Followed	Cited
Bodin v. Stategreen texcrimapp · 1991 · cited in 5 Texas opinions naming this issue, 2007–2021 2 sentences 2021See Bodin v. State, 807 S.W.2d 313, 316 (Tex. Crim. 2015See Bodin, 807 S.W.2d at 319 .	5	5
Bailey v. Stategreen texapp · 1991 · cited in 2 Texas opinions naming this issue, 2004–2012 2 sentences 2012See Bailey v. State, 804 S.W.2d 226, 230 (Tex. App.—Amarillo 1991, no pet.). 2012Id.	2	2
Olivarez v. Stategreen texapp · 2005 · cited in 2 Texas opinions naming this issue, 2008–2021 2 sentences 2021Olivarez v. State, 171 S.W.3d 283, 292 (Tex. App.—Houston [14th Dist.] 2005, no pet.). 2008App. 1991); Olivarez v. State, 171 S.W.3d 283 , 293–94 (Tex. App.—Houston [14th Dist.] 2005, no pet.). 4 made a plausible showing that he was entitled to have the trial court conduct an in-camera hearing.7 We overrule points two, three, and four.	1	2
Ford v. Stategreen texapp · 2005 · cited in 1 Texas opinions naming this issue, 2012–2012 1 sentence 2012Ford v. State, 179 S.W.3d 203, 210 (Tex. App.—Houston [14th Dist.] 1995, pet. ref'd).	1	1
Anderson v. Stategreen texcrimapp · 1991 · cited in 1 Texas opinions naming this issue, 2008–2008 1 sentence 2008Therefore, appellant has not 5 … See Vasquez, 67 S.W.3d at 240 . 6 … Anderson v. State, 817 S.W.2d 69, 72 (Tex. Crim.	1	1
Blondett v. Stategreen texapp · 1996 · cited in 1 Texas opinions naming this issue, 2003–2003 1 sentence 2003Cf. id. (“Evidence submitted to the court shall be sealed and preserved to be made available to the appellate court in the event of an appeal.”).	1	1
Wofford v. Stategreen texapp · 1995 · cited in 1 Texas opinions naming this issue, 2001–2001 1 sentence 2001Wofford v. State, 903 S.W.2d 796, 798 (Tex.App.—Dallas 1995, pet. ref d) (citing Tex.R.	1	1
Holloway v. Stategreen texapp · 1985 · cited in 1 Texas opinions naming this issue, 1988–1988 1 sentence 1988See Bellah v. State, 653 S.W.2d 795, 796 (Tex.Crim.App.1983).” Holloway, supra at 117 .	1	1
Bellah v. Stategreen texcrimapp · 1983 · cited in 1 Texas opinions naming this issue, 1988–1988 2 sentences 1988See Bellah v. State, 653 S.W.2d 795, 796 (Tex.Crim. 1988See Bellah v. State, 653 S.W.2d 795, 796 (Tex.Crim.App.1983).” Holloway, supra at 117 .	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Also cited on this issue (10)

Case	Cited	Years
Hall v. State green texapp · 1988 2 sentences 1996Appellant relies on Hall v. State, 778 S.W.2d 473 (Tex.App.—Houston [14th Dist.] 1988, pet. refd), to argue that a court can hold an in camera hearing only when it is requested by the State. 1996Appellant relies on Hall v. State , 778 S.W.2d 473 (Tex. App.--Houston [14th Dist.] 1988, pet. ref'd), to argue that a court can hold an in camera hearing only when it is requested by the State.	2	1996–1996
v. Lujan green colo · 2020 1 sentence 2024Having a bailiff and court reporter present, “while not a substitute for real-time public observation, certainly served to remind the court. . . of [it’s] responsibilities and provide a check on possible bias.” Lujan, 461 P.3d at 496 (quoting Schierman, 438 P.3d at1082).	1	2024–2024
Reyna v. State green texcrimapp · 2005 1 sentence 2023Id. at 174–75.	1	2023–2023
Long v. State green texapp · 2004 2 sentences 2022Long v. State, 137 S.W.3d at 732 . 2022Id.	1	2022–2022
Hammer v. State green texcrimapp · 2009 1 sentence 2014EVID. 608(b); Hammer, 296 S.W.3d at 562 - 1 Indeed, appellant’s counsel argued the following at the in-camera hearing: To show that those are stories that are inconsistent and that are consistent with—with my theory of the case, which is that because of mental health issues or because of her desires to do something different from time to time that she would—that she would fabricate, and that’s the crux of the entire case, Your Honor, and if I’m not permitted to question the witness—the complaining witness about these various stories, then I’m left unable to establish the most important aspects	1	2014–2014
Montgomery v. State green texcrimapp · 1991 1 sentence 2014Id.	1	2014–2014
Vasquez v. State green texcrimapp · 2002 1 sentence 2008Therefore, appellant has not 5 … See Vasquez, 67 S.W.3d at 240 . 6 … Anderson v. State, 817 S.W.2d 69, 72 (Tex. Crim.	1	2008–2008
Lewis v. United States green scotus · 1892 2 sentences 1985Appellant argues that he has a fundamental right to be present at every stage of his trial and to be able to confront all witnesses against him, citing Lewis v. United States, 146 U.S. 370 , 13 S.Ct. 136 , 36 L.Ed. 1101 (1892); Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Pointer v. Texas, 380 U.S. 400 , 85 S.Ct. 1065 , 13 L.Ed.2d 923 (1965); U.S. CONST, amend. 1985Appellant argues that he has a fundamental right to be present at every stage of his trial and to be able to confront all witnesses against him, citing Lewis v. United States, 146 U.S. 370 , 13 S.Ct. 136 , 36 L.Ed. 1101 (1892); Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Pointer v. Texas, 380 U.S. 400 , 85 S.Ct. 1065 , 13 L.Ed.2d 923 (1965); U.S. CONST, amend.	1	1985–1985
Pointer v. Texas green scotus · 1965 2 sentences 1985Appellant argues that he has a fundamental right to be present at every stage of his trial and to be able to confront all witnesses against him, citing Lewis v. United States, 146 U.S. 370 , 13 S.Ct. 136 , 36 L.Ed. 1101 (1892); Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Pointer v. Texas, 380 U.S. 400 , 85 S.Ct. 1065 , 13 L.Ed.2d 923 (1965); U.S. CONST, amend. 1985Appellant argues that he has a fundamental right to be present at every stage of his trial and to be able to confront all witnesses against him, citing Lewis v. United States, 146 U.S. 370 , 13 S.Ct. 136 , 36 L.Ed. 1101 (1892); Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Pointer v. Texas, 380 U.S. 400 , 85 S.Ct. 1065 , 13 L.Ed.2d 923 (1965); U.S. CONST, amend.	1	1985–1985
Illinois v. Allen green scotus · 1970 2 sentences 1985Appellant argues that he has a fundamental right to be present at every stage of his trial and to be able to confront all witnesses against him, citing Lewis v. United States, 146 U.S. 370 , 13 S.Ct. 136 , 36 L.Ed. 1101 (1892); Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Pointer v. Texas, 380 U.S. 400 , 85 S.Ct. 1065 , 13 L.Ed.2d 923 (1965); U.S. CONST, amend. 1985Appellant argues that he has a fundamental right to be present at every stage of his trial and to be able to confront all witnesses against him, citing Lewis v. United States, 146 U.S. 370 , 13 S.Ct. 136 , 36 L.Ed. 1101 (1892); Illinois v. Allen, 397 U.S. 337 , 90 S.Ct. 1057 , 25 L.Ed.2d 353 (1970); Pointer v. Texas, 380 U.S. 400 , 85 S.Ct. 1065 , 13 L.Ed.2d 923 (1965); U.S. CONST, amend.	1	1985–1985

Statutes the citing opinions construe

TX § Tex. Penal Code § 12.42 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 28 (1982–2026) FL 23 (1981–2020) OK 22 (1980–2017) TX 20 (1985–2024) GA 15 (1986–2016) OH 13 (1997–2023) NY 9 (1991–2013) MI 7 (2008–2025) PA 6 (1986–2026) WV 4 (1995–2024) NJ 4 (1994–2024) AR 3 (2015–2023) CO 3 (1971–2026) ID 3 (1985–2023) NC 3 (1982–2017) SD 3 (1972–2000) NM 2 (1984–2013) IA 2 (1975–2014) WY 2 (2010–2025) MA 2 (1991–1994)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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