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Allan B. Polunsky Unit houses the State of Texas death row for men.

Key Information

Huntsville Unit, where Ward was put to death

Adam Kelly Ward (August 11, 1982[1] – March 22, 2016[2]) was an American convicted murderer executed by the U.S. state of Texas by lethal injection.

Early life

[edit]

Ward was born in the North Texas city of Commerce, Texas, located just under an hour from Dallas, TX to Dr. Ralph Ward, an industrial engineer, and Nancy Ward, who worked in banking and as a staff member in higher education. Adam Ward attended the public schools in Commerce and was diagnosed from an early age of having behavior disorders as well as learning disabilities such as dyslexia. Both his parents and teachers noted that while Ward was clearly intelligent, his behavioral issues were a detriment to his education. After high school, Ward briefly attended Paris Junior College, but dropped out. In the few days preceding the murder, Ward had lost a job that according to his father, he very much enjoyed and was hoping to turn into a career.

Murder

[edit]

On June 13, 2005, while washing his car, Adam Ward encountered Michael Walker, a 44-year-old code enforcement officer, taking photographs of Ward's home in Commerce, Texas. Ward's home had been frequently cited by the City of Commerce for numerous code violations over the previous five years. Walker taking pictures agitated Ward, according to testimony. Walker then had a brief encounter with Ward, who advised him to leave the area.[1][3] Walker went to his truck, moved it to the opposite side of the street and called the police, while Ward ran to his bedroom and returned outside with a handgun, and started to fire at Walker. He chased Walker while he retreated behind his truck according to witnesses, and tried to hide behind and under it. When Walker tried to run down the street, Ward shot him again, making for a total of nine shots fired at Walker.[4] Walker's father, Dick Walker, was serving with the Commerce Emergency Corps and arrived on the scene shortly before his son died.[5]

Victim

[edit]

The victim was 44-year-old Michael "Pee Wee" Walker. Walker had been a construction worker before being hired by the City of Commerce as a code enforcement officer. Walker lived with his father, Dick Walker, a funeral director who owned and operated a funeral home in Commerce. Walker also had two children, a son Donavon and a daughter Marissa who lived with him and his father in Commerce.

Trial

[edit]

Ward was charged with murder in obstruction/retaliation, making him eligible for the death penalty.[6] While a pretrial inmate, Ward was held in the Hunt County Jail. His capital murder trial began in June 2007 under District Attorney F. Duncan Thomas.[5] Ward's attorneys pleaded not guilty and Ward claimed he acted in self defense as he claimed Walker was a threat to him. His attorneys presented information to the court that claimed that Ward was mentally ill and had delusions. Hunt County prosecutors alleged Ralph Ward instilled paranoia in his son against governmental institutions in the Commerce area, including the city government, the Commerce Independent School District, and the Commerce Police Department.[5] Ralph Ward had previously been involved in a public feud with Commerce ISD over the education methods used to teach Adam and he sometimes appeared at his schools unexpectedly.[7] There was a history of confrontations between Walker and the Wards, and Adam said he felt afraid for his safety. Walker was unarmed when Ward killed him.[4] After the trial, Ward was convicted and sentenced to death.[8]

Execution

[edit]

Ward, Texas Department of Criminal Justice (TDCJ) 999525, was held on men's death row at the Polunsky Unit near Livingston, Texas.[1] He was executed on March 22, 2016, at the Huntsville Unit in Huntsville, Texas.[2] Ward stated: "This is wrong what's happening," he said. "This is not a capital case; it never was a capital case; I had never intended to do anything. A lot of injustice is happening in all this. I'm sorry things didn't work out. May God forgive us all." A spiritual adviser and three friends of his attended his execution; his parents did not attend it. Ward was pronounced dead at 6:34 CT, 12 minutes after the drugs started to flow.[6]

Aftermath and Reaction

[edit]

Numerous anti-death penalty advocates condemned the execution, citing it as unconstitutional due to claims that Ward was mentally ill. Commerce police Chief Kerry Crews, who attended the execution, said it was a tragedy for both families, and that hopefully the execution could "provide closure so that they can move on." Dick Walker later filed a civil suit against the City of Commerce and The Ward Family for wrongful death, and settled out of court. The City of Commerce then sued Ralph Ward in an attempt to gain permission to demolish the home, as it had already been declared condemned. In the fall of 2019, The City of Commerce had the Ward house demolished and the property lot cleared.

See also

[edit]

References

[edit]
[edit]
Revisions and contributorsEdit on WikipediaRead on Wikipedia

Adam Kelly Ward

View on Grokipedia
from Grokipedia
Adam Kelly Ward (August 11, 1982 – March 22, 2016) was an American convicted of for shooting to death a municipal officer in , and executed by . On June 13, 2005, Ward, then 22, fatally shot 46-year-old Michael Walker, a city officer, multiple times with a while Walker photographed accumulated junk vehicles and debris on Ward's property during an inspection for violations. Ward confronted Walker amid ongoing disputes over property maintenance, firing after Walker attempted to leave the scene. Following his arrest, Ward was tried in Hunt County; a convicted him of in June 2007 and imposed a death sentence after determining he posed a future danger to society. Extensive appeals, including claims of incompetence and severe mental disorders such as , , and paranoid delusions documented since childhood, were rejected by state and federal courts, which upheld his competency to stand trial and the validity of the proceedings. Ward was executed on March 22, 2016, at the , marking one of the cases where mental illness arguments failed to halt under distinguishing it from exemptions.

Personal Background

Early Life and Family Environment

Adam Kelly Ward was born on August 11, 1982, in Hunt County, Texas. He was raised in Commerce, a small city in the same county, where his family resided in a property that accumulated repeated citations for housing and zoning violations from local authorities. Ward's father, Ralph Beck Ward, shared responsibility for the property maintenance issues, as evidenced by a civil lawsuit filed against both father and son alleging negligence in the events leading to a 2005 incident. The family maintained contact with Ward into adulthood, as he spoke by phone with both parents on the day of his execution in 2016. From , Ward displayed behavioral challenges within his and settings, including toward peers and extreme oppositional conduct that strained parent-child relations. He attended public schools in , where these issues manifested in disruptive classroom behavior starting in elementary years. The household environment, characterized by persistent disputes, fostered a context of conflict with municipal officials that persisted into Ward's early adulthood. No detail siblings or extended dynamics, though the father's professional background in industrial mechanics influenced Ward's interests in mechanical work.

Behavioral and Mental Health History

Ward exhibited early signs of behavioral disturbances, displaying unusual aggressiveness as a young child. By age two, he showed indicators of mental illness consistent with later diagnoses. He was diagnosed with at age four and prescribed , a typically used for mood stabilization in such conditions. Ward was hospitalized on two occasions during childhood for extended periods due to acute manifestations of his mental illness. During middle school, Ward's behavioral issues intensified, including frequent use of degrading and vulgar language toward teachers and peers, chronic tardiness, early departures from class, and resistance to authority. Delusional tendencies emerged by , escalating into paranoid ideation by adolescence. He struggled academically despite evident intelligence, as noted by parents and educators, with behavioral problems impeding progress. Ward was unable to maintain full-time employment into adulthood, reflecting ongoing instability. A psychiatric at his 2007 trial diagnosed Ward with a psychotic disorder characterized by paranoid delusions, contributing to distorted perceptions of threats. Upon arrest in 2005, a jail screening documented him as depressed, hostile, and lacking insight into his circumstances. Appeals courts later acknowledged his lifelong mental illness, including and , though these did not alter findings of competency or premeditation in the offense.

The Offense

Code Enforcement Conflict

The Ward family residence in , had accumulated multiple violations of local and codes prior to the incident, primarily involving improper outdoor storage of items and the accumulation of junk vehicles and debris. The City of issued numerous citations to the household for failing to comply with these ordinances, which aimed to maintain property standards and prevent . At one point, city officials issued a demolish order for the home due to the extent of the non-compliance, reflecting the protracted nature of the enforcement efforts. These repeated citations created ongoing tension between the Wards and city authorities, as the family resisted cleanup and abatement measures. On June 13, 2005, officer Michael Walker returned to the property on Caddo Street to document the continuing violations, specifically photographing the unsheltered storage and piled-up junk that violated municipal codes. This routine inspection, part of standard procedure for persistent offenders, escalated into a when Adam Kelly Ward, a resident of the home, approached Walker while armed. Ward later claimed the encounter involved , asserting that Walker posed a threat, though evidence indicated Walker was unarmed and focused solely on evidentiary photography.

Details of the Murder

On June 13, 2005, Michael Walker, a officer for the of , arrived at the Ward family home to document a violation involving unsheltered storage of trash and junk accumulated in the yard. At the time, Adam Kelly Ward was washing his car outside the residence when Walker began taking photographs to record the code infraction, leading to an argument between the two men. Ward's father, Ralph Ward, attempted to de-escalate the situation, but Ward escalated it further by spraying Walker with a hose. Walker then radioed for assistance from a , prompting Ralph Ward to advise him to leave the property. Before Ralph Ward could further intervene, Adam Ward retrieved a .45 from inside the house, ran toward Walker, and opened fire, striking him multiple times despite Walker's attempts to flee down the street. Walker, who was unarmed, sustained a total of nine wounds; after he fell across the sidewalk, Ward approached and fired additional shots at close range. Walker was pronounced dead at the scene from the gunshot wounds. Ward later confessed to authorities, stating that he believed the city was targeting his family in retaliation for prior disputes. The shooting was classified as under law, as it occurred in the course of obstructing or retaliating against Walker's official duties.

The Victim

Profile of Michael Walker

Michael Edmond Walker, commonly known as "Pee Wee" among colleagues and community members, was a 44-year-old resident of , , at the time of his death. Born on May 1, 1961, he was the son of Richard "Dick" Andrew Walker, a local figure who outlived him and passed away in 2017. Walker was a father to at least two children; in 2016, his father referenced his grandchildren—Walker's offspring—as being aged 19 and 21, indicating they were born in the mid-1990s during Walker's mid-30s. A wrongful lawsuit filed by his and children against parties connected to the Ward family property resulted in a awarding millions in damages in May 2009, though recovery was unlikely due to the defendants' financial status. The City Hall later honored Walker by naming a conference room after him, reflecting his local recognition beyond his professional duties. A memorial service marked the one-year anniversary of his death in June 2006, attended by community members in .

Professional Role and Community Impact

Michael Walker served as a housing and zoning officer for the city of , responsible for inspecting properties and documenting violations such as accumulated junk and structural issues to ensure compliance with municipal standards. On , 2005, Walker, aged 44, was performing routine duties by photographing code violations at a residence on Caddo Street when he was fatally shot multiple times. Walker's work contributed to maintaining public safety and aesthetic standards in Commerce, a small city in Hunt County, by addressing blighted properties that could harbor hazards or detract from neighborhood quality. Colleagues and city officials remembered him affectionately as "Pee Wee," noting his dedication to these enforcement tasks despite inherent risks. His death marked the first on-duty killing of a code enforcement officer in Texas history, as recognized by the Code Enforcement Association of Texas, raising awareness about the vulnerabilities faced by municipal inspectors confronting non-compliant property owners. In recognition of his service, the city of Commerce named a conference room at City Hall the Michael “Pee Wee” Walker Conference Room, where local boards and committees continue to meet, symbolizing his enduring legacy in civic operations. A community memorial service was held one year after his death, reflecting the local impact of his loss on residents and public servants.

Trial and Evidence Presentation

The trial of Adam Kelly Ward for the of Michael Walker commenced in 2007 in , following his arrest on June 13, 2005. Ward was charged with intentionally murdering Walker, a city code enforcement officer, while in the course of committing obstruction or retaliation against a public servant, elevating the offense to under law. Prosecutors presented evidence that Ward ambushed Walker from a distance while the victim was photographing code violations—junk vehicles and debris—outside the Ward family property, firing initial shots that struck Walker, who was unarmed, before approaching and delivering a fatal close-range shot to his head as he lay dying. Ward's post-arrest confession, in which he admitted to "overreacting" to Walker's presence, was introduced, along with ballistic evidence linking the gunfire to a weapon recovered from Ward's possession. The prosecution's case emphasized the premeditated nature of the attack, portraying it as retaliation for ongoing disputes rather than , with no corroborating Ward's claims of prior police beatings or imminent threat from Walker. Forensic detailed the trajectory and multiplicity of wounds—multiple shots from varying distances—undermining any narrative of reflexive action. Eyewitness accounts from family members or neighbors, if any, were not highlighted in appellate reviews, but the scene reconstruction via photographs and Walker’s official duties log confirmed his lawful presence solely for inspection purposes. Ward's defense centered on mental illness as a and potential bar to culpability, introducing extensive records of his history of delusions, , and through multiple expert evaluations. Psychiatrists proffered reports diagnosing conditions including , with testimony asserting that Ward's perceptions of persecution—framed around as government conspiracy—impaired his rationality at the time of . Lay witnesses, including family, recounted Ward's erratic behavior predating the incident, such as prior assaults and violations tied to untreated episodes. However, the defense did not pursue a formal under standards, instead offering the evidence to negate intent during the guilt-innocence phase, though the jury rejected these arguments in finding Ward guilty of .

Conviction and Sentencing

In June 2007, a Hunt County jury convicted Adam Kelly Ward of for the intentional shooting death of Michael Walker on June 13, 2005, while Ward was committing or attempting to commit retaliation or obstruction. The capital murder indictment specified that Ward used a during the offense, elevating the charge under Penal Code provisions for committed in the course of obstructing governmental functions. During the punishment phase, the jury deliberated the statutory special issues required in Texas capital cases: whether Ward posed a future danger to society and whether sufficient mitigating evidence warranted a life sentence instead. The jury answered affirmatively on future dangerousness and negatively on mitigation, leading to a recommendation of death. On June 27, 2007, District Judge B. F. "Beacom" Wright accepted the jury's verdict and formally sentenced Ward to death by lethal injection, as mandated by Texas law for capital murder convictions with affirmative special-issue findings. Ward displayed no visible reaction to the sentencing. The conviction and sentence were later affirmed on direct appeal by the Texas Court of Criminal Appeals in 2010.

Appeals and Controversies

Challenges to Conviction

Ward's direct appeal to the challenged the validity of his conviction on several grounds related to the guilt-innocence phase, including the legal and factual sufficiency of the evidence to prove he intentionally caused Michael Walker's death during the commission of a ( of Walker's ), errors in the charge that allegedly permitted a non-unanimous verdict on the underlying , and ineffective assistance of trial counsel for failing to object to certain prosecutorial arguments and evidentiary admissions. The court held that the evidence— including Ward's confession, ballistic matches linking the murder weapon to casings at the scene, and witness testimony placing Ward at the location—was sufficient to support the 's finding of guilt beyond a , rejected the charge complaints as not preserving error or lacking harm under state law, and determined that counsel's actions did not meet the deficient performance standard under given the strategic context and lack of prejudice. The conviction was affirmed on February 10, 2010. In subsequent state habeas corpus applications filed under Texas Code of Criminal Procedure Article 11.071, Ward reiterated claims of trial court errors in admitting extraneous offense evidence and during closing arguments, but the convicting court recommended denial after findings of fact, and the adopted those recommendations without live hearings, deeming the claims procedurally barred or meritless. Federal habeas review under 28 U.S.C. § 2254 followed, where Ward pressed claims directly attacking the conviction, notably at the guilt phase for inadequate investigation into his history, which allegedly led to reliance on flawed expert testimony diagnosing rather than presenting evidence of or delusions that could have supported a diminished capacity defense. He also alleged a Sixth Amendment violation from a juror's exposure to Dr. Paul Zelhart, a prosecution expert, during lunch, claiming it biased deliberations. The U.S. District Court for the Northern District of denied Ward's federal petition in full on September 24, 2014, finding state court resolutions neither contrary to nor an unreasonable application of clearly established federal law. The Fifth Circuit Court of Appeals refused a certificate of appealability on January 22, 2015, holding that the state habeas denial of the guilt-phase IAC claim was reasonable because trial counsel had allocated over $136,000 for mental health experts who testified extensively, and no prejudice resulted given the overwhelming forensic and confessional evidence of intent. The jury contact claim failed for lack of evidence of influence, as Zelhart's confirmed no discussion of the case, and jurors denied prejudice. The U.S. denied on October 5, 2015, exhausting challenges to the conviction. All courts consistently upheld the trial evidence as robust, including Ward's multiple gunshot wounds to Walker at close range on September 21, 2005, corroborating premeditation over any mental defect negating intent.

Mental Illness Claims and Competency Debates

Ward underwent pretrial competency evaluations in 2007 conducted by psychologists Dr. Heidi Vermette and Dr. Kristi Compton, who concluded he was competent to stand trial notwithstanding his documented conditions. A separate neuropsychological evaluation by Dr. Randall Price that year affirmed diagnoses of (persecutory type) and bipolar mood disorder, yet supported the competency finding. The trial court accepted these assessments, proceeding with and the trial. Ward's mental health history included a diagnosis at age 4, for which he received treatment, alongside escalating aggressive and antisocial behaviors from early childhood. By , he displayed delusional tendencies, and by age 15, he routinely interpreted neutral events as personal threats or attacks. Additional diagnoses encompassed , depression, oppositional-defiant disorder, shared psychotic disorder, and with narcissistic and obsessive-compulsive traits. During the 2007 penalty phase, a testified to Ward's psychotic disorder manifesting in paranoid delusions, including beliefs in conspiracies and targeted threats against him. Appellate proceedings featured defense claims that Ward's lifelong severe mental illness—evidenced by two multi-week hospitalizations in adolescence—rendered him categorically ineligible for execution under the Eighth Amendment, akin to prohibitions on executing those with intellectual disabilities. The affirmed his conviction and death sentence on February 10, 2010, rejecting related ineffective-assistance arguments for insufficient mitigation investigation. In federal habeas review, the U.S. Fifth Circuit Court of Appeals denied a certificate of appealability on January 22, 2015, ruling that no precedent barred execution for non-intellectually disabled individuals with mental illness, regardless of severity. Pre-execution challenges invoked (1986), asserting Ward's delusions impaired his rational understanding of the execution's purpose and connection to his offense, but courts determined his mental state did not meet the incompetency threshold. The U.S. declined to intervene on March 22, 2016, hours before his , upholding prior findings that his and bipolar symptoms, while chronic, did not preclude competency at execution. Appeals courts consistently acknowledged Ward's mental illness but distinguished it from legal bars to , emphasizing that general psychiatric diagnoses alone do not override statutory future-dangerousness assessments.

Execution

A clemency submitted on behalf of Adam Kelly Ward to the Texas Board of Pardons and Paroles was rejected on March 18, 2016, five days before his scheduled execution. The highlighted Ward's documented history of severe mental illness, including paranoid delusions and incompetence findings during pretrial proceedings, arguing these factors warranted commutation to . On March 22, 2016, hours prior to the execution, Ward's attorneys filed an emergency appeal to the U.S. Supreme Court, contending that evolving standards of decency prohibited executing individuals with profound mental illness, as recognized by federal appeals courts throughout his case, and invoking precedents like Atkins v. Virginia (2002) by analogy despite Ward not meeting intellectual disability criteria. The Court denied the stay without comment, allowing the execution to proceed, consistent with its prior October 2015 refusal to grant certiorari on related claims. This followed the Texas Court of Criminal Appeals' rejection of Ward's final state habeas application earlier that week, where a concurring opinion by Judge Elsa Alcala acknowledged the absence of statutory exemptions for non-intellectually disabled mentally ill defendants but urged legislative reform.

Execution Process and Last Moments

Adam Kelly Ward was executed by lethal injection on March 22, 2016, at the Huntsville Unit in Huntsville, Texas, the state's primary facility for carrying out capital sentences. The procedure followed Texas Department of Criminal Justice protocols, beginning with Ward being escorted to the execution chamber, where he was secured to a gurney with restraints. Two intravenous catheters were inserted into his veins, typically in the arms, by trained medical personnel screened for anonymity. Witnesses, separated by glass partitions, included victims' family members, Ward's supporters, media, and officials; the chamber allowed for audio transmission of the inmate's final statement but not conversation between parties. Prior to the administration of drugs, Ward delivered a final statement lasting about five minutes, in which he thanked his friends, family, and legal team for their support throughout his incarceration. At 6:22 p.m. CST, prison officials initiated the lethal injection sequence with a single dose of pentobarbital, the sole drug used in Texas executions at that time to induce unconsciousness, respiratory arrest, and cardiac failure. As the pentobarbital took effect, Ward reportedly stated, "I feel it," indicating awareness of the drug's onset, before becoming unresponsive. He was pronounced dead at 6:34 p.m. by medical staff, confirming cessation of heartbeat and brain activity, marking the completion of the 12-minute process from injection to death. No complications were reported in the execution, consistent with the state's use of compounded pentobarbital sourced domestically.

Reactions and Implications

Immediate Aftermath

Following Ward's execution by at the on March 22, 2016, he was pronounced dead at 6:34 p.m. CT, approximately 12 minutes after the administration of the drugs. In his final statement, Ward expressed remorse to his parents, grief for the victim Michael Walker and Walker's two children, and hope for forgiveness from Walker's family, while thanking supporters who attended. Dick Walker, father of the victim and a to the execution, described the event as providing closure to the "mental anguish" and "" endured by his family since Michael's death in , stating, "I'm glad it's over." Prior to the execution, Dick Walker had publicly forgiven Ward, indicating he no longer harbored anger toward him. Anti-death penalty advocates and mental health organizations immediately criticized the execution, emphasizing Ward's documented history of delusions, , and —conditions acknowledged by federal appeals courts but deemed insufficient to bar under prevailing legal standards. Groups such as the highlighted the case as illustrative of broader concerns over executing individuals with severe mental illnesses, arguing it violated evolving standards of decency despite Ward's competency determinations during trial and appeals. officials, including the Department of Criminal Justice, proceeded without further comment on the mental health debates, marking Ward as the fifth execution in the state that year.

Broader Discussions on Justice and Deterrence

Ward's execution on March 22, 2016, intensified ongoing debates about the justice of applying capital punishment to individuals with severe mental illnesses, raising questions of proportionality and Eighth Amendment protections against cruel and unusual punishment. Courts had acknowledged Ward's history of delusions, bipolar disorder, and paranoia—manifesting from early childhood, including lithium prescriptions by age four and institutionalizations—but rejected arguments that these rendered execution unconstitutional, distinguishing mental illness from intellectual disability barred by Atkins v. Virginia (2002). Critics, including legal scholars and mental health advocates, contended that such executions undermine retributive justice by punishing those lacking full moral culpability due to impaired rationality, potentially exacerbating systemic errors in trials where mental health evidence is undervalued. This perspective gained traction post-execution, prompting a 2017 Texas legislative bill to exempt those with severe mental illness from the death penalty, though it failed amid concerns over defining "severe" illness and potential loopholes for evasion. Proponents of the execution emphasized accountability for heinous acts, arguing that mental illness does not absolve deliberate violence—Ward's IQ tested as high as 123, and state experts deemed him competent—maintaining that justice demands retribution regardless of psychiatric factors short of legal insanity. These discussions highlight tensions in U.S. jurisprudence, where the has not extended categorical exemptions to severe mental illness, leaving states like to execute despite ethical critiques from bodies such as the , which urges exemptions for those whose disorders significantly impaired offense-time functioning. On deterrence, Ward's case underscores skepticism about capital punishment's marginal preventive effect, particularly for offenders driven by rather than rational fear of consequences. Empirical reviews, including the 2012 report, conclude that studies fail to provide robust evidence of deterrence beyond , citing methodological issues like omitted variables and simultaneity in econometric models claiming 3-18 lives saved per execution. For mentally ill perpetrators like Ward, who retrieved a amid perceived threats from , falters under first-principles scrutiny: irrational actors, lacking capacity for consequentialist calculus, are unlikely swayed by execution risks, rendering such punishments symbolically retributive rather than causally preventive. Surveys of criminologists reinforce this, with over 80% deeming the death penalty ineffective as a deterrent. Broader analyses question whether executions like Ward's bolster general deterrence, given inconsistent state-level data: Texas's high execution rate correlates with elevated murder rates compared to non-capital states, challenging claims of systemic incapacitation or marginal effects. While some meta-analyses detect conditional deterrent signals in certain panel studies, these are contested for endogeneity and fail to isolate mental illness subgroups, where no credible supports heightened . Thus, Ward's case exemplifies how capital punishment's deterrence rationale weakens against empirical ambiguity and offender , prioritizing retribution amid unresolved causal debates.

References

  1. https://www.tdcj.texas.gov/death_row/dr_executed_offenders.html
  2. https://www.tdcj.texas.gov/death_row/dr_info/wardadam.html
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  5. https://law.justia.com/cases/texas/court-of-criminal-appeals/2010/19251.html
  6. https://www.texastribune.org/2016/03/22/execution-set-man-courts-recognize-mentally-ill/
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  9. https://www.ketr.org/2009-05-12/family-of-slain-commerce-officer-awarded-millions
  10. https://caselaw.findlaw.com/court/tx-court-of-criminal-appeals/1729661.html
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