Case Citator › Matson v. State

Matson v. State

Is it still good law? What later courts have actually done to this case.

Overruled in part
Court
Texas Court of Criminal Appeals
Citation
819 S.W.2d 839
Decided
Confirmed treatments
1
Flagged citations read
128 of 128
Citing cases (total)
1,540
Treatment dates
2010
Overruled in part
A reviewed court has overruled part of this case’s holding. Matson v. State was overruled in part. The Texas Court of Criminal Appeals replaced the grand-jury due-diligence rule that Matson had applied when an indictment alleged an unknown manner or means.
More on how this was screened

Its separate rule for reviewing evidentiary sufficiency remains in use. All 128 flagged citations have been read; the confirmed treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

1,540 later cases cite Matson v. State; 128 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Matson v. State?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Overruled in Part

  • The Texas Court of Criminal Appeals overruled the grand-jury due-diligence rule that Matson had applied and replaced it with a procedure for challenging an “unknown” allegation before the jury charge is submitted.

    Sanchez v. State · Texas Court of Criminal Appeals · filed

    Thus, we overrule the two-pronged rule in Hicks and announce a new standard for indictments with "unknown" allegations to the grand jury that are subsequently used as the jury charge at trial: ... Hicks, 860 S.W.2d, at 424 ("When an indictment alleges that the manner or means of inflicting the injury is unknown and the evidence at trial does not establish the type of weapon used, a prima facie showing is made that the weapon was unknown to the grand jury. Matson v State, 819 S.W.2d 839, 847 (Tex. Cr. App. 1991). However, if the evidence at trial shows what object was used to inflict the injury, then the State must prove that the grand jury used due diligence in attempting to ascertain the weapon used.").
    Read the full opinion on CourtListener →

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