Ex Parte Wilkinson

Some of our earlier cases are consistent with the view that Article 24.05 and Section 21.002 are irreconcilable. In Ex Parte Wilkinson, 641 S.W.2d 927, 932-33 (Tex. Crim. App. 1982), the trial court held a witness in contempt for failing to testify before a grand jury in violation of Article 20.15 of the Code of Criminal Procedure, which provides penalties, including jail, for refusing to testify after being compelled to appear before a grand jury. There we held that the more specific statute, Article 20.15, prevailed over the more general contempt statute, Article 1911a of the Civil Statutes (now Section 21.002 of the Government Code).