Ex Parte Rachael Ann Sheridan, 02-16-00254-CR

Background

Appellant Rachael Sheridan was arrested after police found firearms, explosives, and bomb-making materials in a pickup occupied by her, her husband (who used the name "Ryan Webb" but was actually Joshua Mitchell), and their children. Her child identified the materials as the father’s explosives.
Sheridan was charged with two counts of endangering a child, arrested, and placed in jail; CPS temporarily removed the children and initiated termination proceedings against both parents.
Facing incarceration that would impede completion of a court-ordered service plan (necessary to avoid parental termination), Sheridan pleaded guilty on December 2, 2010 to both counts, received probated two-year sentences and five years’ community supervision; plea paperwork and judgment recited that the plea was voluntary and that she was admonished.
Mitchell’s parental rights were terminated; Sheridan’s were not, and she later received early termination of community supervision in 2013.
In April 2016 Sheridan filed an article 11.072 habeas application claiming duress/involuntariness of her plea (she said she pleaded guilty to get out of jail quickly and start services) and asserting innocence; the State submitted plea forms, police reports, and investigation reports.
The trial court denied relief without an evidentiary hearing, adopting proposed findings that (1) Sheridan knowingly, voluntarily pleaded guilty; (2) she failed to present newly discovered evidence of innocence; and (3) evidence supported a finding she knew of explosive materials. Sheridan appealed; the court of appeals affirmed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an evidentiary hearing was required under art. 11.072	Sheridan: Hearing necessary to evaluate voluntariness and termination-proceeding evidence	State: Hearing not required; trial court may decide on submitted documents	Court: No hearing required; trial court did not abuse discretion (article 11.072 permits but does not mandate hearing)
Burden of proof for showing plea involuntary	Sheridan: Plea was involuntary due to duress (need to begin service plan, inability to post bond)	State: Prima facie showing that plea was voluntary via written admonitions; burden shifted to Sheridan to rebut	Court: State made prima facie showing; Sheridan bore heavy burden to defeat presumption and failed to do so
Admission of termination-proceeding findings/evidence	Sheridan: Termination-court findings support innocence and should affect habeas relief	State: Those findings don’t control criminal collateral attack; trial court need not consider unfiled testimony	Court: Trial court properly declined to consider evidence not presented below; termination findings don’t nullify plea presumption
Voluntariness/duress claim based on jail pressure and parental-rights risk	Sheridan: Plea induced by need to avoid losing parental rights and get out of jail sooner	State: Plea was a calculated, voluntary choice after counsel reviewed options	Court: Evidence shows plea was a knowing, voluntary, intelligent choice; duress claim failed

Key Cases Cited

Ex parte Mello, 355 S.W.3d 827 (Tex. App.—Fort Worth 2011) (deferential review of habeas court findings)
Ex parte Cummins, 169 S.W.3d 752 (Tex. App.—Fort Worth 2005) (article 11.072 does not require evidentiary hearing)
Martinez v. State, 981 S.W.2d 195 (Tex. Crim. App. 1998) (written admonitions create prima facie showing plea was voluntary)
State v. Guerrero, 400 S.W.3d 576 (Tex. Crim. App. 2013) (presumption that written-judgment recitals are correct)
Ex parte Mable, 443 S.W.3d 129 (Tex. Crim. App. 2014) (standard for voluntariness of plea: intelligent choice among alternatives)
Ex parte Palmberg, 491 S.W.3d 804 (Tex. Crim. App. 2016) (defendant accepts risk when pleading guilty)
Ex parte Whisenant, 443 S.W.3d 930 (Tex. Crim. App. 2014) (supplemental habeas evidence generally must be submitted first to trial court)
Herrera v. Collins, 506 U.S. 390 (U.S. 1993) (actual-innocence framework referenced)