Charles Douglas McClain, III v. State, 06-14-00104-CR

Appellant Charles Douglas McClain, III appealed his conviction raising ineffective assistance of counsel and the admission of his oral statements. The State filed a reply brief defending the conviction.
At police request McClain came to the station voluntarily for a noncustodial interview and later agreed to a polygraph; Sergeant Derrick Walker advised him of rights before the polygraph interview and recorded the session.
McClain made incriminating admissions during the polygraph-related interview; the State elicited those admissions at the bench trial while avoiding any explicit mention of the polygraph.
Defense counsel asked the court for probation during the punishment phase; McClain waived a jury trial.
No motion-for-new-trial hearing or testimony from trial counsel explaining trial strategy was placed on the record. Defense did file a pretrial motion to suppress statements but never pursued a hearing or renewed the issue at trial.

Issue	Appellant's Argument	State's Argument	Held
Whether trial counsel was constitutionally ineffective	Counsel erred (e.g., asked for probation, waived jury) and that performance prejudiced outcome	Record is silent on counsel’s strategy; no egregious error shown; appellate record inadequate to prove Strickland deficiency	Appellee argues counsel was effective; appellate court should not find deficiency on silent record
Whether Appellant's oral statements were improperly admitted under Art. 38.22 (custodial interrogation)	Statements taken in violation of custodial-interrogation safeguards so should be suppressed	Statements were made voluntarily in a noncustodial setting; petitioner was free to leave; State redacted polygraph references and properly admitted admissions	Appellee argues statements admissible because no custody and Art. 38.22 protections did not apply

McMann v. Richardson, 397 U.S. 759 (recognizes right to competent counsel but not errorless representation)
Strickland v. Washington, 466 U.S. 668 (establishes two-part test for ineffective assistance of counsel)
Stansbury v. California, 511 U.S. 318 (custody inquiry: whether a reasonable person would feel free to terminate the interview)
Lopez v. State, 343 S.W.3d 137 (Texas standard on appellate review of ineffective-assistance claims; presumption of reasonable professional judgment)
Menefield v. State, 363 S.W.3d 591 (appellate courts should not find counsel ineffective on a silent record unless conduct is outrageous)
State v. Saenz, 411 S.W.3d 488 (articulates scenarios constituting custody for Miranda/Art. 38.22 analysis)
Wright v. State, 154 S.W.3d 235 (addresses admissibility and redaction of polygraph-related statements)