Harrison v. State, 333 S.W.3d 810

Appellant Warren Harrison was charged with felony murder and convicted by jury, receiving 25 years' confinement.
The offense arose from a November 2, 2006 confrontation at Tianna Rivers's apartment, where Harrison and others confronted Tianna and Laurie Rivers over alleged stolen money.
Tianna pulled a kitchen knife; Laurie directed Tianna to fetch a pistol; Harrison attempted to shoot but the gun’s safety prevented firing until he later fired at Tianna and Laurie.
Harrison shot Tianna in the leg and Laurie in the chest, killing Laurie.
During voir dire, Harrison asked questions about time for voir dire, prior juries, self-defense doctrine, and gun ownership; the court eventually limited time and denied a formal additional-time ruling.
Harrison moved for additional time to conduct voir dire; the court noted 44 minutes had been allotted and declined further extended questioning.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there abuse of discretion denying extra voir dire time?	Harrison asserts he needed more time to ask pertinent voir dire questions.	State contends the court properly limited time and Harrison did not prove improper questions or need to prolong.	No abuse; time limits upheld.
Did Harrison waive error by affirmatively stating no objection to seating of the jury?	Harrison did not preserve error by initial objections; later objections were not preserved.	Waiver occurred because Harrison twice said no objection to jury seating.	Waiver affirmed; points of error 1–3 overruled.
Did counsel's voir dire performance constitute ineffective assistance?	Ineffective performance due to failings in questioning during voir dire.	Record shows reasonable, strategic conduct; no deficient performance established.	Appellate court found representation reasonable; no ineffective-assistance violation.

Sells v. State, 121 S.W.3d 748 (Tex. Crim. App. 2003) (abuse of discretion standard for jury selection; broad trial court discretion)
Whitaker v. State, 653 S.W.2d 781 (Tex. Crim. App. 1983) (time limits on voir dire considered reasonable; one more question not automatic abuse)
McCarter v. State, 837 S.W.2d 117 (Tex. Crim. App. 1992) (two-prong test for voir dire timing; need to show intent to prolong and proper questions)
Robertson v. State, 187 S.W.3d 475 (Tex. Crim. App. 2006) (totality of representation standard for ineffective assistance)
Rylander v. State, 101 S.W.3d 107 (Tex. Crim. App. 2003) (prejudice element required to prove ineffective assistance)
Goodspeed v. State, 187 S.W.3d 390 (Tex. Crim. App. 2005) (counsels' strategy and reasons for conduct must be evidenced; outrageousness standard)
Bone v. State, 77 S.W.3d 828 (Tex. Crim. App. 2002) (cannot speculate motives; must be firmly founded in record)
Jackson v. State, 491 S.W.2d 155 (Tex. Crim. App. 1973) (voir dire questioning may be dictated by trial strategy)
Williams v. State, 970 S.W.2d 182 (Tex. App.-Houston [14th Dist.] 1998) (selective questioning and strategy upheld as reasonable trial tactics)
Swain v. State, 181 S.W.3d 359 (Tex. Crim. App. 2005) (affirmative no objection can waive trial objections in voir dire context)
Moraguez v. State, 701 S.W.2d 902 (Tex. Crim. App. 1986) (properly assessing objections to evidence or procedures during trial)