English-speaking defendant in Texas

2009See United States v. Cirrincione, 780 F.2d 620, 633-34 (7th Cir.1985); United States ex rel.

2009See United States v. Cirrincione , 780 F.2d 620, 633-34 (7th Cir. 1985); United States ex rel.

2009See, e.g., Montoya v. State, 811 S.W.2d 671, 673 (Tex.App.-Corpus Christi 1991, no pet.) (Spanish-speaking defendant who failed to direct reviewing court "to any part of the record where alleged errors in translation occurred which prevented him from confronting the witnesses” waived his right to complain of the use of a bailiff as a translator); Frescas v. State, 636 S.W.2d 516, 518 (Tex.App.-El Paso 1982, no pet.) (non-English-speaking defendant did not establish harm where he failed to show, from the record, specific misunderstandings or inability to confront a witness).

2009See, e.g., Montoya v. State , 811 S.W.2d 671, 673 (Tex. App.--Corpus Christi 1991, no pet.) (Spanish-speaking defendant who failed to direct reviewing court "to any part of the record where alleged errors in translation occurred which prevented him from confronting the witnesses" waived his right to complain of the use of a bailiff as a translator); Frescas v. State , 636 S.W.2d 516, 518 (Tex. App.--El Paso 1982, no pet.) (non-English-speaking defendant did not establish harm where he failed to show, from the record, specific misunderstandings or inability to confront a witness).

2009See, e.g., Montoya v. State, 811 S.W.2d 671, 673 (Tex.App.-Corpus Christi 1991, no pet.) (Spanish-speaking defendant who failed to direct reviewing court "to any part of the record where alleged errors in translation occurred which prevented him from confronting the witnesses” waived his right to complain of the use of a bailiff as a translator); Frescas v. State, 636 S.W.2d 516, 518 (Tex.App.-El Paso 1982, no pet.) (non-English-speaking defendant did not establish harm where he failed to show, from the record, specific misunderstandings or inability to confront a witness).

2009See, e.g., Montoya v. State , 811 S.W.2d 671, 673 (Tex. App.--Corpus Christi 1991, no pet.) (Spanish-speaking defendant who failed to direct reviewing court "to any part of the record where alleged errors in translation occurred which prevented him from confronting the witnesses" waived his right to complain of the use of a bailiff as a translator); Frescas v. State , 636 S.W.2d 516, 518 (Tex. App.--El Paso 1982, no pet.) (non-English-speaking defendant did not establish harm where he failed to show, from the record, specific misunderstandings or inability to confront a witness).

2014In Ling , the Georgia Supreme Court rejected trial counsel’s claimed strategy in failing to secure an interpreter for a non-English-speaking defendant “on the basis that he was concerned using an interpreter might cause the jury to grow impatient and did not want to draw too much attention to the fact that [the defendant] was not a native English speaker.” Id.

2014In Ling, the Georgia Supreme Court rejected trial counsel’s claimed strategy in failing to secure an interpreter for a non-English-speaking defendant “on the basis that he was concerned using an interpreter might cause the jury to grow impatient and did not want to draw too much attention to the fact that [the defendant] was not a native English speaker.” Id.

2015See, e.g., United States v. Carrion, 488 F.2d 12, 14 (1st Cir. 1973). (“Clearly, the right to confront witnesses would be meaningless if the accused could not 27 understand their testimony, and the effectiveness of cross-examination would be severely hampered.”).