Madden v. State

In Madden v. State, 911 S.W.2d 236, 241-42 (Tex. App.--Waco 1995, pet. ref'd), the defendant argued that the trial judge should have disqualified herself because she had prosecuted him in another case before she became a judge. The Court explained that the prohibition against a judge hearing a case in which she had been counsel does not include prior cases having no relation to the case before the court. Madden, 911 S.W.2d at 240.