You are viewing a free summary from Descrybe.ai. For citation checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.

Ex Parte Franklin Jose Velasquez Martinez

Citation: Not availableDocket: 04-22-00387-CR

Court: Court of Appeals of Texas; July 13, 2022; Texas; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

Appellant Franklin Jose Velasquez Martinez filed a timely notice of appeal regarding the trial court's denial of his application for a pre-trial writ of habeas corpus. Under Texas Rule of Appellate Procedure 25.2(a)(2), the trial court is required to provide a certification of the defendant's right to appeal whenever it issues a judgment of guilt or other appealable orders, including pre-trial habeas decisions. The court noted that the denial of relief in a pre-conviction habeas corpus proceeding is immediately appealable as it constitutes a separate criminal action, marking the end of the trial stage of that action. The Fourth Court of Appeals ordered the trial court to execute a written certification confirming the defendant's right to appeal the denial of his pre-trial habeas corpus application. Additionally, the district clerk must file a supplemental record with this certification within ten days of the order.

Legal Issues Addressed

Appealability of Pre-conviction Habeas Corpus Decisions

Application: The denial of a pre-conviction habeas corpus application is immediately appealable as it marks the end of the trial stage of that action.

Reasoning: The court noted that the denial of relief in a pre-conviction habeas corpus proceeding is immediately appealable as it constitutes a separate criminal action, marking the end of the trial stage of that action.

Certification of Right to Appeal

Application: The trial court is required to provide a certification of the defendant's right to appeal in pre-trial habeas corpus proceedings.

Reasoning: Under Texas Rule of Appellate Procedure 25.2(a)(2), the trial court is required to provide a certification of the defendant's right to appeal whenever it issues a judgment of guilt or other appealable orders, including pre-trial habeas decisions.

Filing Supplemental Records

Application: The district clerk is required to file a supplemental record with the certification of the defendant's right to appeal within a specified timeframe.

Reasoning: Additionally, the district clerk must file a supplemental record with this certification within ten days of the order.

Mandate for Written Certification

Application: The appellate court ordered the trial court to execute a written certification confirming the defendant's right to appeal the denial of his pre-trial habeas corpus application.

Reasoning: The Fourth Court of Appeals ordered the trial court to execute a written certification confirming the defendant's right to appeal the denial of his pre-trial habeas corpus application.