Texas v. Heilman (original by judge keasler)
Annotate this CaseEric Heilman pled guilty to misdemeanor tampering with a governmental record after the relevant two-year statute of limitations had expired. In October 2008, Heilman was serving as an officer with the Beaumont Police Department. Along with another officer and a confidential informant, Heilman took part in a failed undercover narcotics sting targeting a suspected drug dealer. Although no transaction occurred, when the suspect began to leave, Heilman pursued and arrested him, seizing cash and a large amount of cocaine. But when Heilman drafted his probable-cause affidavit on October 13, 2008, he failed to mention either the undercover operation or his confidential informant. In return for Heilman’s plea, the State agreed not to pursue indictment for state-jail felony tampering with a governmental record. In an application for a writ of habeas corpus, Heilman challenged the trial court’s jurisdiction to accept his plea to the time-barred offense, arguing that his “pure law” limitations defense was a category-one absolute right under "Marin v. Texas." The habeas court granted relief, and the court of appeals affirmed. After review, the Court of Criminal Appeals reversed: "Heilman’s attempt to renege on his guilty plea after accepting its benefits exposes the unintended consequences of our prior holding in Phillips v. State. To ensure the sanctity and finality of plea agreements reached in good faith and at arm’s length, we will no longer unquestioningly distinguish between factual and pure-law limitations defenses. Instead, in circumstances lacking any legislative ex post facto violation - and especially when that occurs in the context of a good-faith, arm’s length plea agreement - both are Marin category three forfeitable rights. [. . . ] Therefore, because there was no ex post facto violation, the trial court properly exercised its jurisdiction to accept Heilman’s plea and Heilman had every right to forfeit (or in this case waive) his limitations defense as part of that plea. We reverse the holdings of the habeas court and the court of
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