Gboweh Dickson George v. State, 446 S.W.3d 490

George was convicted of murder and sentenced to 75 years in prison by a Harris County trial court.
The offense involved shooting at an apartment where a child victim and others were present; the 11-year-old was killed, and others were injured.
During pretrial and trial, George intermittently disrupted proceedings, interrupted witnesses, and refused to communicate with counsel and the court.
The court conducted an informal competency assessment and ultimately determined there was no evidence of incompetence, denying a formal competency hearing.
George was removed from the courtroom and placed in a holdover cell at various times, with the court attempting to preserve his rights while maintaining trial order.
The State introduced numerous photographs, including images of the victim, which the court admitted over defense objections; the trial proceeded to verdict and punishment phase.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there an informal competency inquiry.	George claims the court did not engage in informal inquiry.	State contends inquiry occurred, but no formal hearing needed absent evidence of incompetence.	No error; informal inquiry found no incompetence.
Exclusion from the courtroom.	George argues removal violated right to be present and was unnecessary.	State relies on Allen to justify removal for disruptive conduct.	No reversible error; court did not abuse discretion.
Mistrial denial.	George contends ongoing misconduct tainted the jury requiring mistrial.	State argues alternative measures sufficed and no extreme prejudice remained.	No abuse of discretion; mistrial denied.
Jury instruction on absence.	George requests instruction to disregard his absence during guilt phase and punishment.	No binding authority required such instruction; defendant cannot create reversible error by own conduct.	No error; instruction not required.
Evidentiary photographs.	Photographs were inflammatory and prejudicial to the defense.	Photos depicted the reality of the offense and aided jurors; probative value outweighed prejudice.	Photographs properly admitted; no abuse of discretion.

Luna v. State, 268 S.W.3d 594 (Tex. Crim. App. 2008) (informal competency inquiry; deference to trial court findings)
Turner v. State, 422 S.W.3d 676 (Tex. Crim. App. 2013) (competency standard and evaluation guidance)
Ex parte LaHood, 401 S.W.3d 45 (Tex. Crim. App. 2013) (informal inquiry scope and evidence standard)
Moore v. State, 999 S.W.2d 385 (Tex. Crim. App. 1999) (disruptive demeanor not probative of incompetence)
Chamberlain v. State, 998 S.W.2d 230 (Tex. Crim. App. 1999) (photographs as probative scene evidence; nondispositive prejudicial concerns)
Beasley v. State, 634 S.W.2d 320 (Tex. Crim. App. 1982) (own misconduct cannot create reversible error)