Spielbauer v. Texas (original by judge keel)
Annotate this CaseThe veniremembers summoned for Appellant Jeffrey Spielbauer’s non-death, capital-murder trial were required to answer a questionnaire that asked, among other things, whether they had heard about Appellant’s case and formed an opinion about his guilt or innocence. Six veniremembers answered these questions yes, and the trial court, over Appellant’s objection, questioned them individually about their answers. Ultimately the trial court denied Appellant’s for-cause challenges to two of these veniremembers, and Appellant complained about those rulings on appeal. The court of appeals reversed, finding that Article 35.16(a)(10) required dismissal of the veniremembers based on their questionnaires. The State petitioned the Texas Court of Criminal Appeal, which reversed, finding the parties here agreed the questionnaires were answered before voir dire began. Thus, they were not part of formal voir dire, and the answers they prompted would not by themselves support a challenge for cause or compel Article 35.16(a)(10)’s injunction against further interrogation. Therefore, the Court found the trial court did not abuse its discretion in personally questioning the veniremembers who answered yes to the two questions at issue here.
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