Diamond v. Texas (original by judge newell)
Annotate this CaseAndrea Gooden was a laboratory technician who properly analyzed Appellant Lesley Diamond's blood for alcohol content in this case. After Appellant’s trial, it was revealed that Gooden had - before trial - mistakenly certified a blood alcohol analysis report in an unrelated case where a police officer had mislabeled the submission form accompanying a blood sample. Due to her self-report of the erroneous certification to her supervisor, Gooden had been temporarily removed from casework at the time of Appellant’s trial so she could research and document this incident. The prosecutors in this case, unaware of the problem in the unrelated case, failed to disclose this information to Appellant prior to Gooden’s testimony in Appellant’s trial. The question before the Texas Court of Criminal Appeals was whether that evidence is material. The post-conviction habeas court concluded it was not and denied Article 11.072 relief. Based upon its review of the trial record, the Court of Criminal Appeals agreed and reversed the court of appeals’ holding to the contrary, and upheld the habeas court’s ruling.
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