Williams v. State of Texas (original by presiding judge keller)
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In the case before the Court of Criminal Appeals of Texas, the defendant, Jemadari Chinua Williams, was charged with aggravated promotion of prostitution. The indictment against him followed the language of the relevant statute, which enumerated six potential methods of committing the offense. Williams filed a motion to quash the indictment on the grounds that the State was required to specify which of the six methods it would rely on to establish his guilt. The trial court denied the motion and Williams was convicted.
On appeal, Williams argued that the indictment was insufficient as it failed to specify the manner and means of committing the offense. The court of appeals reversed the trial court's decision, concluding that the State was required to pick one of the methods allowed by statute and alleged in the indictment to satisfy the notice requirement.
Upon review, the Court of Criminal Appeals of Texas disagreed with the court of appeals, holding that the State is not required to elect between alternative statutory methods of committing an offense alleged in an indictment. The Court noted that the maxim requiring the State to specify the manner of commission applies when a statute defines an offense in multiple ways and is an exception to the general rule that statutory definitions do not have to be included in a charging instrument. The Court clarified that this rule can require the State to allege more detail in a charging instrument, but it does not require the State to abandon a manner or means in the charging instrument. Accordingly, the Court reversed the judgment of the court of appeals and remanded the case for consideration of Williams's remaining points of error.
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