Coty, Leroy Edward, 432 S.W.3d 341

Cot y pleaded guilty to possession with intent to distribute at least 400 grams; pleaded to lesser-included offense under Health & Safety Code §481.115(f).
After a lab technician’s malfeasance was discovered, Coty filed a habeas corpus petition; relief was initially granted and then reconsidered.
Texas Court of Criminal Appeals adopted a new analytical framework in 2014 for forensic-misconduct claims, remanding for application of that framework.
Habeas court found State rebutted an inference of falsity and that the evidence was not material to Coty’s conviction.
Court independently reviewed and affirmed the habeas court’s findings and denial of relief.
Key evidence cited includes chain-of-custody details, uniform representations by lab personnel, video of evidentiary handling, initialing/dating of exhibits, and corroborating tests and K-9 alert.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an inference of falsity was established under the framework.	Coty shows five misconduct factors for inference.	State rebutted the inference of falsity.	State rebutted presumption of falsity.
Whether the false evidence was material to Coty’s conviction.	False evidence would have affected guilt.	Abundant independent evidence shows guilt.	Evidence not material to conviction.
Whether the State adequately rebutted the inference of falsity.	Record supports misconduct and falsity.	Record shows no misconduct affecting result.	State's rebuttal supported by record and video/K-9 evidence.

Ex parte Coty, 418 S.W.3d 597 (Tex. Crim. App. 2014) (adopts modified false-evidence framework for forensic-misconduct claims; requires materiality showing)
Ex parte Chavez, 371 S.W.3d 200 (Tex. Crim. App. 2012) (materiality standard for false evidence)