Issac Smith v. State, 14-14-00139-CR

A 71-year-old woman was murdered in her home; her van was stolen. Appellant (Issac Smith) lived across the street and was arrested after approaching the crime scene; DNA linked him to the victim’s van, purse, and under her fingernails.
A jailhouse informant (cellmate in 2012) testified that appellant confessed to robbing, sexually assaulting, and killing the victim, providing details corroborated by other evidence.
The informant had competency/sanity evaluations from December 2010 diagnosing paranoid schizophrenia and noting hospitalizations and past hallucinations; records recommended psychotropic medication, but the State represented he was then only on anti-anxiety medication.
Defense sought to impeach the informant with his mental-health history; the trial court ruled the defense could ask about current medications but precluded inquiry into prior diagnoses/psychotic history. Defense did not make an offer of proof outside the jury’s presence.
The jury convicted appellant of capital murder; he was sentenced to life without parole. On appeal, appellant argued the trial court abused its discretion by excluding cross-examination of the informant’s mental-health history and raised a Confrontation Clause claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether excluding cross-examination into the informant’s mental-health history violated Smith’s confrontation/right to impeach	Smith: He should have been allowed to impeach informant with 2010 schizophrenia diagnosis and hospitalizations to attack credibility	State: Defense did not preserve a Confrontation Clause claim; trial court appropriately limited inquiry to current meds and excluded remote psychiatric diagnoses absent a showing of relevance to competency at relevant times	Court: Smith failed to preserve a Confrontation Clause/objective evidentiary challenge; even if preserved, exclusion was within trial court’s discretion and any error was harmless

Oprean v. State, 201 S.W.3d 724 (Tex. Crim. App.) (abuse-of-discretion standard for evidentiary rulings)
Reyna v. State, 168 S.W.3d 173 (Tex. Crim. App.) (requirements to preserve Confrontation Clause claims and to articulate grounds for admissibility)
Virts v. State, 739 S.W.2d 25 (Tex. Crim. App.) (when and how mental-illness evidence may be used to impeach credibility)
Perry v. State, 236 S.W.3d 859 (Tex. App.—Texarkana) (preservation and harm analysis where mental-health impeachment was sought)
Shelby v. State, 819 S.W.2d 544 (Tex. Crim. App.) (test for assuming maximum damaging effect of excluded impeachment and factors for harmless-error review)
King v. State, 953 S.W.2d 266 (Tex. Crim. App.) (substantial-rights standard under Tex. R. App. P. 44.2(b))