Rios v. State

In Rios v. State, 4 S.W.3d 400, 402 (Tex. App.--Houston [1st Dist.] 1999, pet. dism'd) the Court opined, following Gonzales, that, while harmless error review under Rule 44.2(a) is the correct standard for determining constitutional error when proper voir dire questions are denied, it was not possible to conduct a meaningful harm analysis in most cases or in that case because the only way to attempt to measure the harm would be to ask the jurors the proposed voir dire questions. The Court decided Rios, however, before it had the benefit of later opinions from the Court of Criminal Appeals directing various appellate courts to conduct a harm analysis.