In Anderson v. State, 301 S.W.3d 276 (Tex. Crim. App. 2009), Anderson filed an unsworn oral motion for continuance--thus failing to comply with the procedural requirements of Articles 29.03 and 29.08 of the Texas Code of Criminal Procedure--in order to mount a defense against the State's DNA test results. In overruling the court of appeals' decision that Anderson's claim was preserved on the basis of a due process exception to the rule that an unsworn oral motion for a continuance preserves nothing for review, the court determined that a meaningful opportunity to present a complete defense is a right subject to forfeiture. Accordingly, Anderson was obliged to file a written, sworn motion for continuance in order to preserve his complaint for appellate review. Id. The Court of Criminal Appeals was confronted with the issue of whether there is a "due process exception" to the statutory requirements for a continuance motion. See Anderson, 301 S.W.3d at 278-80. In reviewing the denial of an oral motion for continuance, the Corpus Christi court of appeals concluded a party may appeal the denial of a continuance if it amounted to a due-process denial, specifically the right to present a defense. Id. at 278. Thus, the appellate court acknowledged the procedural requirement, but overcame it by invoking a "due process exception." Id. at 278. The Court of Criminal Appeals held that the Corpus Christi court erred in concluding the appellant need not preserve the error because the right to present a complete defense is subject to forfeiture if not properly preserved. Id. at 279-80 (discussing "there is nothing to prohibit Articles 29.03 and 29.08 as operating as a rule of procedural default"). Because there is no "due process exception" to the preservation requirements of Articles 29.03 and 29.08, the Court of Criminal Appeals held the appellant failed to preserve his claim. Id. at 280-81.