DueProcess Punishment Jurisdiction
Did the trial court's failure to submit any instruction to the jury regarding Texas' corpus delicti rule and the subsequent endorsement of that failure by the Fourteenth Court of Appeals of Texas, deprive the Petitioner of his right to a jury trial jury guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution in direct contravention of this Court's decisions in Apprendi v. New Jersey and its progeny?
QUESTION PRESENTED Texas has adopted a corpus delicti rule requiring that an extra-judicial confession have a quantum of corroboration before a conviction can be had based on it. It is well settled in Texas that its corpus delicti rule is one of “evidentiary sufficiency” and applies to the aggravating factors elevating a simple murder to a capital murder. Here, Texas used an extrajudicial confession as proof that the Petitioner committed murder in the course of committing robbery, the element that elevated the case to a capital, rather than a “simple,” murder. The trial court below failed to instruct the jury about Texas’s corpus delicti rule, even though corroboration was an essential fact without which the Petitioner could not have been convicted of capital murder or subjected to the dramatically elevated punishment range he ultimately faced. Did the trial court’s failure to submit any instruction to the jury regarding Texas’ corpus delicti rule and the subsequent endorsement of that failure by the Fourteenth Court of Appeals of Texas, deprive the Petitioner of his right to a jury trial jury guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution in direct contravention of this Court’s decisions in Apprendi v. New Jersey and its progeny? 1 PARTIES Christopher Williams is the Petitioner. Respondent is the State of Texas. 2