David Garcia Reyes v. State, 06-14-00228-CR

David Garcia Reyes was convicted by a jury of sexual assault of a child and sentenced to 15 years’ imprisonment.
At pretrial, the State disclosed the child-victim participated in DACA and had inquired about U-Visa eligibility; the State moved in limine to exclude immigration evidence.
Reyes argued the victim’s immigration status and immigration applications were relevant to motive to fabricate.
The trial court granted the State’s motion in limine and excluded the proffered immigration-related evidence at trial after the State objected as irrelevant and highly prejudicial.
On appeal Reyes claimed the exclusion violated his Sixth Amendment Confrontation Clause rights; he also sought correction of the judgment’s mislabeling of the offense.
The court held Reyes forfeited his Confrontation Clause claim for lack of timely, specific invocation at trial, but ordered the judgment amended to correctly name the offense as sexual assault of a child.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excluding evidence of the victim’s immigration status violated Reyes’s Confrontation Clause right	Excluding the immigration evidence prevented meaningful confrontation and cross-examination; it was probative of motive to fabricate	The evidence was irrelevant to fabrication and highly prejudicial; the objection at trial invoked evidentiary rules, not the Confrontation Clause	Forfeited — Reyes did not timely and specifically invoke the Confrontation Clause at trial, so appellate review of that constitutional claim is barred
Whether the trial court’s judgment misnamed the offense and must be corrected	Reyes: judgment labels offense as "sexual continuous assault of a child" but indictment and charge reflect single-count sexual assault of a child; judgment should be amended	State: agrees the label is incorrect and supports modification	Modified — court corrected the judgment to reflect the offense as sexual assault of a child

Lopez v. State, 18 S.W.3d 220 (Tex. Crim. App. 2000) (Confrontation Clause can require admissibility despite evidence rules)
Clark v. State, 365 S.W.3d 333 (Tex. Crim. App. 2012) (constitutional errors may be forfeited if not properly raised at trial)
Reyna v. State, 168 S.W.3d 173 (Tex. Crim. App. 2005) (objection must specifically invoke confrontation or error is not preserved)
Jones v. State, 843 S.W.2d 487 (Tex. Crim. App. 1992) (insufficient specificity in offers of proof results in forfeiture on appeal)
French v. State, 830 S.W.2d 607 (Tex. Crim. App. 1992) (appellate courts may reform judgments when the record provides necessary information)