Ex parte Seidel

In Ex parte Seidel, 39 S.W.3d 221, 226-27 (Tex. Crim. App. 2001), an opinion decided less than a year ago, a majority of this Court held that a trial court's dismissal of a prosecution with prejudice was "void" and that it could be collaterally attacked. 39 S.W.3d 221. The Court specifically stated that "the trial judge's action was more than a mere violation of statutory procedure. The trial judge's action was not authorized by law and was, therefore void." Id at 225. The Court also recognized that other "non-jurisdictional" errors, such as "illegal" or "unauthorized" punishments, can render a judgment void and, therefore, subject to collateral attack. Id. at 225 and n.4.