Christopher Henry v. the State of Texas, 03-21-00562-CR

Christopher Henry is indicted for capital murder and sought bail reduction via writs of habeas corpus and motions for release on reasonable bail.
Henry filed 17 pro se habeas applications and four counseled motions seeking bail reduction; he attempted to appeal a denial allegedly occurring on October 4, 2021.
The only record reference to October 4 is a docket-sheet entry reading "Motion is Denied" under "Orders of Court."
The record contains no signed, written order disposing of any of Henry’s bail applications or motions; the Bell County District Clerk confirmed no signed order exists.
The district court certified the ruling is "not a final order and is not appealable."
The Court of Appeals concluded it lacked jurisdiction and dismissed the appeal for want of jurisdiction.

Issue	Henry's Argument	State/District Court's Argument	Held
Whether an interlocutory denial of a pretrial motion for bond reduction is appealable	Henry seeks review of the district court's October 4 denial of his habeas application for bail reduction	Interlocutory denials of pretrial bond motions are not appealable	Denied—such interlocutory denials are not appealable (Ragston)
Whether denial of a pretrial application for writ of habeas corpus concerning bail may be appealed	Henry contends the habeas denial is reviewable on appeal	Habeas challenges to bail are reviewable only if there is a signed, appealable order disposing of the application	Appeal requires a signed, written order; without one appellate jurisdiction is lacking
Whether a docket-sheet entry constitutes a signed, appealable order	Henry relies on the docket entry "Motion is Denied" as the basis for appeal	A docket-sheet entry is not a signed written order and does not constitute an appealable order	Held: docket entries do not constitute appealable orders; a signed order is required
Whether the record must include a trial-court certification that the defendant has a right of appeal	Henry argues the appeal is proper despite lack of formal certification	Rule requires certification of the defendant's right to appeal be part of the record	Held: absent certification showing a right of appeal, the appeal must be dismissed

Ragston v. State, 424 S.W.3d 49 (Tex. Crim. App. 2014) (interlocutory denial of pretrial bond-reduction motion is not appealable)
Ex parte Gray, 564 S.W.2d 713 (Tex. Crim. App. 1978) (habeas corpus is the proper method to challenge denial or excessiveness of bail)
Ex parte Gill, 413 S.W.3d 425 (Tex. Crim. App. 2013) (appeal may lie from denial of habeas relief under Art. 17.151 when properly presented)
Smith v. State, 559 S.W.3d 527 (Tex. Crim. App. 2018) (appeal perfection requires a signed, appealable order)
State v. Sanavongxay, 407 S.W.3d 252 (Tex. Crim. App. 2012) (an order must be in writing for appeal purposes)
State v. Rosenbaum, 818 S.W.2d 398 (Tex. Crim. App. 1991) (trial court "enters" an order when the judge signs it)
State v. Shaw, 4 S.W.3d 875 (Tex. App.—Dallas 1999) (docket-sheet entries do not constitute appealable orders)
Dears v. State, 154 S.W.3d 610 (Tex. Crim. App. 2005) (appellate rules require certification that the defendant has a right of appeal be part of the record)