Watkins v. Texas (original by judge newell)
Annotate this CaseThis case concerned the admission of 33 of 34 exhibits during the punishment phase of Appellant Ralph Watkins’ trial for possession with intent to deliver a controlled substance. The exhibits were a collection of booking records, pen packets, and judgments of prior convictions that were used to prove two prior convictions for enhancement and other extraneous offenses that Appellant had committed. Prior to trial, Appellant’s attorney timely requested disclosure of “any other tangible things not otherwise privileged that constitute or contain evidence material to any matter involved in the case” pursuant to Article 39.14 of the Texas Code of Criminal Procedure. The prosecutor provided notice of the State’s intent to introduce evidence of these prior convictions and extraneous offenses at punishment, but the prosecutor didn’t disclose copies of the exhibits themselves until it was time to introduce them. The Texas Court of Criminal Appeals determined the exhibits at issue were “material” because they had a logical connection to subsidiary punishment facts. It therefore reversed the court of appeals and remanded the case so that the court of appeals could analyze whether Appellant was harmed by the lack of disclosure.
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