in Re Alfred Dewayne Brown, 614 S.W.3d 712

Alfred Dewayne Brown was convicted of capital murder in 2005 and spent over 12 years in prison, nearly 10 on death row.
In 2014 the Texas Court of Criminal Appeals vacated his conviction for Brady violations after the prosecutor suppressed exculpatory phone records; the State declined to retry him.
The State moved to dismiss the indictment in 2015 and the district court granted dismissal; Brown sought Tim Cole Act compensation but the Comptroller denied it for lack of an actual-innocence-based habeas grant.
A Harris County special prosecutor investigated and concluded Brown "could not physically have been at the crime scene" and met the legal definition of actual innocence; the District Attorney filed an amended motion to dismiss in 2019 asserting Brown is actually innocent and that no credible inculpating evidence exists.
The district court granted the amended motion and issued an amended dismissal order expressly declaring Brown actually innocent; the Comptroller denied Brown’s Tim Cole Act claim again, reasoning the court lacked jurisdiction to withdraw and reenter dismissal nearly four years after the original dismissal.
Brown petitioned this Court for mandamus, arguing the Comptroller’s duty is purely ministerial and limited to the face of verified documents; the Supreme Court of Texas granted relief, directing the Comptroller to approve Brown’s claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of Comptroller's review under Tim Cole Act	Comptroller's duty is purely ministerial and must be based only on face of verified documents	Comptroller may look beyond documents to ensure legal validity (e.g., court jurisdiction)	Comptroller's duty is purely ministerial and limited to face of verified documents
Validity of amended dismissal (jurisdiction to reenter dismissal)	Amended order is regular on its face and contains required actual-innocence findings	Amended order is facially void/ambiguous because prior dismissal terminated jurisdiction	Court did not decide underlying jurisdictional correctness; held Comptroller cannot make de novo jurisdictional review
Eligibility under §103.001(a)(2)(C)	Brown met all statutory elements (incarceration, habeas relief, amended dismissal, DA and court statements of actual innocence)	Denial justified because dismissal may be legally invalid	Brown’s verified documents satisfy the statute on their face; he is eligible for compensation

In re Phillips, 496 S.W.3d 769 (Tex. 2016) (Comptroller’s duty to calculate compensation is an exclusive, ministerial arithmetic-and-law task)
In re Allen, 366 S.W.3d 696 (Tex. 2012) (criminal-court judgments taken as established for Tim Cole Act; types of actual-innocence claims compensable)
Garcia v. Dial, 596 S.W.2d 524 (Tex. Crim. App. 1980) (court of criminal appeals case holding trial courts lack jurisdiction to reinstate criminal cases after dismissal)
Curry v. Wilson, 853 S.W.2d 40 (Tex. Crim. App. 1993) (holds general jurisdiction may continue after dismissal as to some matters)
In re Woodfill, 470 S.W.3d 473 (Tex. 2015) (ministerial duty triggered by predicate certification; body may not reevaluate predicate facts)