Ex Parte Reyes
No. PD-1277-14
Case Summary written by Luke Luttrell, Staff Member.
PRESIDING JUDGE KELLER delivered the opinion of the unanimous court.
Appellee was charged with domestic-violence assault and pursuant to an agreement, he pled guilty and was placed on community supervision. In his habeas application, appellee attacked the community-supervision judgment on five grounds: (1) his trial attorney failed to inform him that the judgment would result in deportation, (2) his trial attorney was ineffective for inadequately investigating the case, (3) the attorney failed to advise him on the law of self-defense, (4) his guilty plea was not knowingly and intentionally made, and (5) that he was actually innocent of the offense.
The trial court granted relief on the first ground and did not address the remaining four. The court of appeals reversed the trial court, holding that the trial court erred in granting relief on the first ground and the guilty plea was reinstated.
The Court of Criminal Appeals, in deciding whether it should address the remaining four issues, found that it is not required to resolve issues that become moot as a result of the resolution of other issues. So, when a habeas applicant advances multiple issues, the trial court may limit the relief to only one issue, if that resolution does not neglect an issue that would provide greater relief. As a result, the court does not spend time and resources resolving more difficult claims that afford no greater relief.
The Court of Criminal Appeals held that a declaration of actual innocence affords greater relief than granting a new trial because of its impact on the defendant’s reputation. Therefore, the case was remanded for the trial court to consider the appellee’s other claims that the trial court did not resolve. Whether those proceedings involved additional fact-findings or further development of the record was a determination for the trial court. The judgment was reversed and remanded.