Miller v. Texas (original by judge hervey)
Annotate this CaseThe Court of Criminal Appeals granted the State’s petition for review to decide whether the corpus delicti rule was satisfied in this case, and whether the rule continues to serve its intended purpose in this state’s jurisprudence. In late November of 2011, Detective Callahan of the White Settlement Police Department was assigned to investigate a report from Child Protective Services that Appellant had engaged in illicit sexual conduct with his then three-month-old daughter, "Madison." Appellant met Callahan and gave two confessions, the first verbal and the second written. Appellant was charged with four counts of aggravated sexual assault of a child under six years of age for molesting his daughter four times in a period of 27 days. At trial, the State’s computer forensics expert was unable to recover any evidence from Appellant’s computer or the memory card that was in his phone, including a picture Appellant said he took of himself molesting his daughter. According to the expert, Appellant used a computer program to irretrievably delete files and folders on his computer and to erase the contents of his memory card. As a result, no probative evidence could be retrieved from the computer or memory card. The jury convicted Appellant of all four counts and sentenced Appellant to life confinement on each count. On appeal, Appellant argued, in part, that the State failed to establish the corpus delicti of three counts of the four counts with which he was charged by failing to corroborate his confessions as to those counts with independent evidence. After review, the Court decided that a strict application of the corpus delicti rule was unnecessary when a defendant confesses to multiple criminal offenses within a single criminal episode or course of conduct if the crimes confessed to are sufficiently proximate that the underlying policy reasons for the rule are not violated. As a result, the Court reversed the court of appeals and reinstated the judgment of the trial court.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.