Armstrong v. State
In Armstrong v. State, 897 S.W.2d 361 (Tex.Crim.App. 1995), the county attorney personally prosecuted a murder case. See id. at 362.
The jury foreperson had been friends with the county attorney for over twenty-five years. In addition, the foreperson's husband and the county attorney had been each other's best man at their respective weddings and the husband was serving as the county attorney's campaign treasurer during the trial, having already served in that capacity in a previous campaign. Id. at 363.
The foreperson did not reveal any of this information during voir dire. Id. at 362-63. The prospective jurors were asked whether any of them were "so well acquainted with" or "acquainted or associated with" the prosecution staff that it would affect their verdict. Id. at 362.
They were also asked whether they had "any special connection with the County Attorney's office, perhaps a close friend in the office, secretary, investigator or the like" and whether there was anything they could think of that touched on their qualifications to serve on the case. Id. at 362-63.
The Court of Criminal Appeals held that there was no juror misconduct because the jury panel was not asked "the questions needed to elicit the desired information." Id. at 364.