Brown v. Texas (Original)
Annotate this CaseAppellant David Brown was on trial for murder. On what would have been the final day of trial in the guilt phase, appellant sustained a gunshot wound to the head. After a one-day recess, the trial judge ruled that appellant's absence from trial was voluntary because there was evidence that the injury may have been self-inflicted. The court conducted the remainder of the guilt trial and the entire punishment trial in appellant's absence. Appellant appealed the trial court's refusal to hold a formal hearing to determine whether he was incompetent to stand trial after sustaining the gunshot wound. The appellate court held that appellant should have been granted a competence hearing before the jury made its guilt determination and remanded the cause for a new trial. The Court of Criminal Appeals granted the state's petition for discretionary review on four grounds, but because the Court found that the trial court did not follow relevant procedures set out in Texas statutes and Supreme Court precedent, it remanded this case back to that court for a retrospective hearing to determine whether appellant was incompetent at any or all of the guilt and punishment phases and sentencing.
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