Charles Wayne Hines v. State, 396 S.W.3d 706

Hines pleaded guilty to sexual assault of a child; jury assessed 12 years’ imprisonment.
Trial court failed to admonish as required by Tex. Code Crim. Proc. 26.13(a) about possible immigration consequences.
Non-constitutional nature of the error triggered Rule 44.2(b) harmless-error review, with independent record examination.
Record included evidence suggesting Hines was born in Mississippi, implying U.S. citizenship from birth.
Complainant testified about sentencing preferences during punishment phase; admissions challenged for relevance and Rule 403.
Court concluded no reversible error; harm was harmless, and judgment affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Immigration admonition error harmless?	Hines contends failure to admonish affected plea decision.	State argues citizenship evidence renders error harmless.	Harmless error; affirmed citizenship implies no deportation risk.
Admission of victim’s sentencing wishes harmless?	Testimony about sentencing should be excluded as irrelevant/prejudicial.	Evidence potentially admissible; not constitutional error.	Harmless error; no substantial effect on punishment verdict.

VanNortrick v. State, 227 S.W.3d 706 (Tex. Crim. App. 2007) (harmless-error approach for immigration admonitions; citizen status inferred from record)
Cain v. State, 947 S.W.2d 262 (Tex. Crim. App. 1997) (citizenship inference from birthplace where deportation risk discussed)
Stevens v. State, 278 S.W.3d 826 (Tex. App.—Houston [14th Dist.] 2009) (harm analysis for admonition error; citizenship inference considerations)
Anderson v. State, 182 S.W.3d 914 (Tex. Crim. App. 2006) (standard for evaluating whether plea-related errors affected substantial rights)
Johnson v. State, 967 S.W.2d 410 (Tex. Crim. App. 1998) (Rule 44.2(b) harm review framework for non-constitutional errors)
Mayes v. State, 353 S.W.3d 790 (Tex. Crim. App. 2011) (punishment range considerations for sexual assault of a child)