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Gustavo Tijerina Sandoval v. Texas

IFP petition · Court of Appeals of Texas, Thirteenth District, No. 13-18-00392-CR · judgment March 6, 2025


Certiorari denied · December 15, 2025

Questions presented

  1. May a state court that reaches and decides an asserted violation of the Sixth Amendment right to jury trial that has not been waived or forfeited under state law nevertheless affirm under a heightened, state-law harm standard because trial counsel did not object, rather than applying Chapman’s harmless-beyond-a-reasonable-doubt standard?

  2. Does petitioner’s conviction violate the Sixth and Fourteenth Amendments because the jury was authorized to convict without being instructed to find every element of the offense beyond a reasonable doubt?

Counsel of record

For petitioner
Jennae Rose Swiergula
Texas Defender Service

For respondent
Lori Denise Brodbeck
Texas Office of the Attorney General

Case

Conference history
Distributed for 1 conference

Linked docket
25A196

Proceedings

  1. Dec 15 2025
    Petition DENIED.
  2. Nov 26 2025
    DISTRIBUTED for Conference of 12/12/2025.
  3. Nov 19 2025
    Waiver of right of respondent Texas to respond filed.
  4. Oct 31 2025
    Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due December 5, 2025)
  5. Sep 20 2025
    Application (25A196) granted by Justice Alito extending the time to file until November 1, 2025.
  6. Sep 15 2025
    Application (25A196) to extend further the time from October 2, 2025 to November 1, 2025, submitted to Justice Alito.
  7. Aug 19 2025
    Application (25A196) granted by Justice Alito extending the time to file until October 2, 2025.
  8. Aug 15 2025
    Application (25A196) to extend the time to file a petition for a writ of certiorari from September 2, 2025 to November 1, 2025, submitted to Justice Alito.