De Garmo doctrine (Texas) · Go Syfert
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De Garmo doctrine in Texas

8 Texas opinions name it 2 courts 1995–2015 0 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 (12)

CaseFollowedCited
Leday v. Stategreen
texcrimapp · 1998 · cited in 4 Texas opinions naming this issue, 2005–2015
2 sentences

2015App. 1998), the Court of Criminal Appeals abandoned the De Garmo doctrine as applied to certain constitutional, legal, and social guarantees – what the court described as “due process and those individual rights that are fundamental to our quality of life.” Id. at 725 .

2015App. 1998), the Court of Criminal Appeals abandoned the De Garmo doctrine as applied to certain constitutional, legal, and social guarantees – what the court described as “due process and those individual rights that are fundamental to our quality of life.” Id. at 725 .

34
Reyes v. Stategreen
texcrimapp · 1999 · cited in 3 Texas opinions naming this issue, 2005–2013
2 sentences

2013Indeed, the only time that this Court has addressed the De Garmo doctrine since Leday was in Reyes v. State , 994 S.W.2d 151 (Tex. Crim.

2013Indeed, the only time that this Court has addressed the De Garmo doctrine since Leday was in Reyes v. State , 994 S.W.2d 151 (Tex. Crim.

23
McGlothlin v. Stategreen
texcrimapp · 1995 · cited in 2 Texas opinions naming this issue, 2013–2013
2 sentences

2013The De Garmo doctrine encourages this sort of sophistic reasoning instead of focusing the appellate court’s attention of the underlying merits of the alleged error in the particular case. 36 McGlothlin v. State, 896 S.W.2d 183, 191 (Tex. Crim.

2013The De Garmo doctrine encourages this sort of sophistic reasoning instead of focusing the appellate court’s attention of the underlying merits of the alleged error in the particular case. 36 McGlothlin v. State, 896 S.W.2d 183, 191 (Tex. Crim.

22
DeGarmo v. Statered
texcrimapp · 1985 · cited in 3 Texas opinions naming this issue, 1995–2013
2 sentences

2013In De Garmo, this Court held that a defendant who testifies at the punishment stage of trial and admits his guilt to the crime for which he had been found guilty waives any challenge to the sufficiency of the evidence.12 We noted, “The law as it presently exists is clear that such a defendant not only waives a challenge to the sufficiency of the evidence, but he also waives any error that might have 10 Id. 11 A jury convicted Roger De Garmo of capital murder in 1980. 691 S.W.2d at 659 .

1995Id., 691 S.W.2d at 661. 3 The Court reaffirmed the doctrine of waiver and overruled De-Garmo’s challenge to the sufficiency of the evidence.

13
Jacobson, Jonathangreen
texcrimapp · 2013 · cited in 1 Texas opinions naming this issue, 2014–2014
2 sentences

2014Jacobson v. State, 398 S.W.3d 195, 196 (Tex. Crim.

2014Jacobson v. State, 398 S.W.3d 195, 196 (Tex. Crim.

11
Resendez v. Stategreen
texapp · 2005 · cited in 1 Texas opinions naming this issue, 2007–2007
2 sentences

2007In Resendez v. State , 160 S.W.3d 181,184 (Tex. App.-Corpus Christi 2005, no pet.), this Court addressed the De Garmo doctrine and its subsequent abrogation by the court of criminal appeals in Leday .

2007In Resendez v. State , 160 S.W.3d 181,184 (Tex. App.-Corpus Christi 2005, no pet.), this Court addressed the De Garmo doctrine and its subsequent abrogation by the court of criminal appeals in Leday .

11
Reyes v. Stategreen
texapp · 1998 · cited in 1 Texas opinions naming this issue, 2005–2005
2 sentences

2005See Reyes v. State, 971 S.W.2d 737, 737 (Tex.App.-Houston [14th Dist.] 1998) (citing De Garmo, 691 S.W.2d at 660-61 ), rev’d, 994 S.W.2d. 151, 152 (Tex.Crim.App.1999).

2005See Reyes v. State, 971 S.W.2d 737, 737 (Tex.App.-Houston [14th Dist.] 1998) (citing De Garmo, 691 S.W.2d at 660-61 ), rev’d, 994 S.W.2d. 151, 152 (Tex.Crim.App.1999).

11
Cochran v. Stategreen
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2005–2005
2 sentences

2005See Cochran v. State, 107 S.W.3d 96, 100 (Tex.App.-Texarkana 2003, no pet.) ("the [Le-day ] case has ... cast doubt on the continued viability of the De Garmo rule as it relates to sufficiency of the evidence challenges”); Duffy v. State, 33 S.W.3d 17, 22 (Tex.App.-El Paso 2000, no pet.) (stating that "the Court of Criminal Appeals has essentially abrogated the De Garmo doctrine in recent years”).

2005See Cochran v. State, 107 S.W.3d 96, 100 (Tex.App.-Texarkana 2003, no pet.) ("the [Le-day ] case has ... cast doubt on the continued viability of the De Garmo rule as it relates to sufficiency of the evidence challenges”); Duffy v. State, 33 S.W.3d 17, 22 (Tex.App.-El Paso 2000, no pet.) (stating that "the Court of Criminal Appeals has essentially abrogated the De Garmo doctrine in recent years”).

11
Nunez v. Stategreen
texapp · 2003 · cited in 1 Texas opinions naming this issue, 2005–2005
2 sentences

2005See, e.g., Nunez v. State, 117 S.W.3d 309, 321 (Tex.App.-Corpus Christi 2003, no pet.). 3 In doing so, we believe it is important to explain exactly where these decisions went awry.

2005See, e.g., Nunez v. State, 117 S.W.3d 309, 321 (Tex.App.-Corpus Christi 2003, no pet.). 3 In doing so, we believe it is important to explain exactly where these decisions went awry.

11
Duffy v. Stategreen
texapp · 2000 · cited in 1 Texas opinions naming this issue, 2005–2005
2 sentences

2005See Cochran v. State, 107 S.W.3d 96, 100 (Tex.App.-Texarkana 2003, no pet.) ("the [Le-day ] case has ... cast doubt on the continued viability of the De Garmo rule as it relates to sufficiency of the evidence challenges”); Duffy v. State, 33 S.W.3d 17, 22 (Tex.App.-El Paso 2000, no pet.) (stating that "the Court of Criminal Appeals has essentially abrogated the De Garmo doctrine in recent years”).

2005See Cochran v. State, 107 S.W.3d 96, 100 (Tex.App.-Texarkana 2003, no pet.) ("the [Le-day ] case has ... cast doubt on the continued viability of the De Garmo rule as it relates to sufficiency of the evidence challenges”); Duffy v. State, 33 S.W.3d 17, 22 (Tex.App.-El Paso 2000, no pet.) (stating that "the Court of Criminal Appeals has essentially abrogated the De Garmo doctrine in recent years”).

11
Winter v. Stategreen
texapp · 1986 · cited in 1 Texas opinions naming this issue, 1996–1996
2 sentences

1996Herbert v. State, 827 S.W.2d 507, 508 (Tex.App.—Houston [1st Dist.] 1992, no pet.); Winter v. State, 725 S.W.2d 728, 731-34 (Tex.App.—Houston [1st Dist.] 1986, no pet.) (Cohen, J., concurring).

1996Herbert v. State, 827 S.W.2d 507, 508 (Tex.App.—Houston [1st Dist.] 1992, no pet.); Winter v. State, 725 S.W.2d 728, 731-34 (Tex.App.—Houston [1st Dist.] 1986, no pet.) (Cohen, J., concurring).

11
Herbert v. Stategreen
texapp · 1992 · cited in 1 Texas opinions naming this issue, 1996–1996
2 sentences

1996Herbert v. State, 827 S.W.2d 507, 508 (Tex.App.—Houston [1st Dist.] 1992, no pet.); Winter v. State, 725 S.W.2d 728, 731-34 (Tex.App.—Houston [1st Dist.] 1986, no pet.) (Cohen, J., concurring).

1996Herbert v. State, 827 S.W.2d 507, 508 (Tex.App.—Houston [1st Dist.] 1992, no pet.); Winter v. State, 725 S.W.2d 728, 731-34 (Tex.App.—Houston [1st Dist.] 1986, no pet.) (Cohen, J., concurring).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (1)

CaseCitedYears
Jacobson v. State green
texapp · 2011
2 sentences

2013The court of appeals noted that, before it could reach the merits of this claim, it had to decide if the De Garmo doctrine barred it from considering appellant’s claim because he had admitted to the offense during the punishment phase.6 After a lengthy discussion of the development of the De Garmo/Leday doctrine, the court of appeals concluded that no case directly addresses that doctrine’s application to a claim that the State struck at defendant over the shoulders of counsel.7 The court then analyzed “the treatment of this type of error in other contexts” to see if the State’s argument could

2013The court of appeals noted that, before it could reach the merits of this claim, it had to decide if the De Garmo doctrine barred it from considering appellant’s claim because he had admitted to the offense during the punishment phase.6 After a lengthy discussion of the development of the De Garmo/Leday doctrine, the court of appeals concluded that no case directly addresses that doctrine’s application to a claim that the State struck at defendant over the shoulders of counsel.7 The court then analyzed “the treatment of this type of error in other contexts” to see if the State’s argument could

22013–2013

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