Bible v. State

In Bible v. State, 162 S.W.3d 234, 240-42 (Tex. Crim. App. 2005) the court of criminal appeals held that warnings were sufficient even though the interviewing officer only warned the defendant that his statement could be used against him "in court" and did not warn him that the statement could be used against him "at trial." 162 S.W.3d 234, 240-42 (Tex. Crim. App. 2005). There, the court of criminal appeals held that the word "court" is the fully effective equivalent of "trial" because the two required warnings "appear to largely overlap and, in fact, 'court' is the broader term, and is reasonably understood to include the term 'trial.'" Id. at 241. The Court held "the corpus delicti doctrine does not apply to extraneous offenses offered at the punishment phase of a capital murder trial." Bible thus stands for the proposition that the State need not provide evidence to corroborate an accomplice's testimony about an extraneous offense committed by the accused when such evidence is brought forth during the punishment phase of a capital murder trial. Id. In deciding Bible, this state's highest criminal court reasoned that, at the point when a capital jury is considering the accused's punishment, the jury is "not faced with the specter of a totally innocent defendant being convicted for a crime that never occurred solely on the basis of a confession resulting from official coercion or the defendant's own delusions." Id.