Villa v. Texas (Original)
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Appellant was indicted for indecency with a child and aggravated sexual assault. The jury found Appellant not guilty of indecency with a child but guilty of aggravated sexual assault and sentenced him to confinement for fifty years. On appeal, Appellant claimed that he received ineffective assistance of counsel because trial counsel failed to request a jury instruction on the medical-care defense. The court of appeals reversed and remanded, holding that Appellant would have been entitled to an instruction on the medical-care defense if he had requested it. The State filed a petition for discretionary review which the Texas Supreme Court granted on two grounds: (1) whether in this case Appellant was entitled to the instruction on the medical-care defense; and (2) is it necessarily ineffective assistance of counsel to not request a defensive instruction that depends upon convincing the jury that the defendant lied to them under oath when he denied committing the prohibited conduct? The Court determined that, in his trial testimony, Appellant admitted to penetration (as defined by Texas law) which was sufficient to satisfy the admission requirement of the confession and avoidance doctrine as it related to the medical-care defense. Further, the Court concluded that Appellant received ineffective assistance of counsel because the defense was properly raised and trial counsel failed to request a jury instruction on the issue.
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