Latest 3 Cases: In re Commitment of Jeffery Lee Stoddard (Civil Procedure), In re Alfred Dewayne Brown (Criminal Law), In re Pamela Janson (Family ...

Odysseus, Avocados, and Election Litigation Timing

MICHAEL C. DORF

Cornell law professor Michael C. Dorf explains the legal concepts of ripeness and laches, which pertain to the timing of filing a lawsuit, and argues that in the context of election lawsuits, it is far better for courts to relax ripeness rules and risk unnecessary adjudications than to discard the doctrine of laches and risk widespread disenfranchisement and the undermining of confidence in fair elections.

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In re Commitment of Jeffery Lee Stoddard

Docket: 19-0561

Opinion Date: December 18, 2020

Judge: Debra Lehrmann

Areas of Law: Civil Procedure, Criminal Law

The Supreme Court reversed the judgment of the court of appeals reversing a jury's finding that Jeffery Lee Stoddard was a sexually violent predator (SVP) and civilly committing him under Tex. Health & Safety Code chapter 841, holding that the court of appeals applied an improper standard. The court of appeals described the standard governing the factual sufficiency review in which the burden of proof was beyond a reasonable doubt the court of appeals described the standard as requiring the court to weigh the evidence in a neutral light to determined whether the jury's finding was factually insufficient or so against the great weight and preponderance as to be manifestly unjust, shock the conscience, or clearly demonstrate bias. The Supreme Court reversed, holding (1) the court of appeals applied an improper standard that allowed the court to substitute its own judgment for that of a reasonable fact-finder and incorporated a statutory element that chapter 841's text did not support; and (2) a properly conducted factual-sufficiency review in an SVP case requires the appellate court to determine whether, on the entire record, a reasonable factfinder could find beyond a reasonable doubt that the defendant is an SVP.

In re Alfred Dewayne Brown

Docket: 19-0877

Opinion Date: December 18, 2020

Judge: Eva Guzman

Areas of Law: Criminal Law

The Supreme Court conditionally granted Alfred Brown's petition for writ of mandamus challenging the determination of the Comptroller of the State of Texas denying Brown's compensation claim brought after he was found to be wrongfully convicted and imprisoned, holding that Brown was eligible for compensation under the Time Cole Act. See Tex. Civ. Prac. & Rem. Code 103.001-.154. Brown was wrongfully convicted of capital murder and sentenced to death. After serving more than twelve years behind bars, Brown was released from prison when it was determined that the prosecuting attorney withheld and suppressed exculpatory evidence. After securing a judicial declaration of actual innocence Brown sought compensation under the Act for the time he was wrongfully imprisoned. The Comptroller denied the compensation claim, concluding that the district court had jurisdiction to issue an order declaring Brown actually innocent. The Supreme Court conditionally granted Brown's petition for writ of mandamus, holding (1) Brown was eligible for compensation under the Act; and (2) the Comptroller exceeded his authority by considering matters beyond the verified documents to make a de novo jurisdictional determination.

In re Pamela Janson

Docket: 19-1109

Opinion Date: December 18, 2020

Judge: Per Curiam

Areas of Law: Family Law

The Supreme Court conditionally granted relief to Mother on her petition for mandamus and directed the trial court to vacate its order holding Mother in contempt, holding that Mother was entitled to her requested relief. After a hearing, the trial court signed an enforcement order finding Mother in contempt of forty-eight violations of an agreed order the trial court entered upon the separation of Mother and Father. On appeal, Mother argued that the agreed order was too ambiguous to be enforced by contempt. The Supreme Court agreed and granted a writ of mandamus to Mother, holding that the agreed order could not support the contempt order because it did not "set forth the terms of compliance in clear, specific, and unambiguous terms."