Jackson, Samuel Roy, WR-59,058-09

Background

Samuel Roy Jackson (TDCJ #1268721) filed a pro se petition for a writ of habeas corpus in the Texas Court of Criminal Appeals seeking relief from conviction and sentence in Cause No. 913043 (aggravated robbery) in the 183rd District Court, Harris County.
Jackson alleges the original aggravated-robbery complaint (filed May 24, 2002) and the information/indictment are invalid because the jurat was not sworn by the named HPD complainant (Officer M.A. Khan) but bears a signature/initials of “T. William,” who Jackson contends is not an HPD officer or competent affiant under Tex. Code Crim. Proc. art. 15.5.
Jackson contends the allegedly defective complaint produced a void information/indictment that never vested subject-matter or personal jurisdiction in the 183rd District Court, so the jury conviction and the 35‑year sentence are void and his confinement unlawful.
He also argues the State reindicted him for burglary (Cause No. 0952420) arising from the same episode, which he says transferred or altered jurisdictional posture; he claims the trial judge (Joan Huffman) failed to rule on pretrial motions (including motion to set aside the indictment) and thereby violated due process.
Jackson advances factual challenges to the evidence (photographs, chain of custody, lack of fingerprints on the knife, medical records suggesting he was shot in the back), and asserts actual innocence and prosecutorial/complaining‑witness fabrication or perjury.

Issues

Issue	Plaintiff's Argument (Jackson)	Defendant's Argument (State)	Held
Validity of complaint jurat under art. 15.5	Jurat signed by “T. William,” not the complaining HPD officer; complaint therefore invalid and cannot support an information	State would argue the charging instruments and grand-jury indictment cured any complaint defects or that the jurat was valid/authorized	Claim asserted; petition seeks habeas relief — no final Court of Criminal Appeals ruling included in this file
Whether invalid complaint/ information deprived trial court of jurisdiction	Because complaint/information were invalid, the 183rd lacked subject‑matter/personal jurisdiction and judgment is void	State would assert indictment (grand jury) and subsequent proceedings conferred jurisdiction and remedied any prior defect	Claim asserted; relief requested is vacatur and release — no decision shown here
Effect of reindictment for burglary (0952420) on aggravated-robbery prosecution	Reindictment for burglary arising from same episode shifted or altered subject-matter jurisdiction and precluded prosecution on the aggravated-robbery indictment	State would argue reindictment did not divest the court of jurisdiction over the aggravated-robbery prosecution or that any procedural issues were waived or non‑jurisdictional	Claim asserted; petitioner alleges void judgment due to subsequent reindictment; no ruling in record provided
Due process and evidentiary challenges (failure to rule on motions, chain of custody, false testimony)	Judge Huffman refused to rule on motions (motion to set aside indictment, discovery requests, motion to dismiss appointed counsel), preventing due‑process review; evidentiary defects and chain-of-custody problems undermined conviction	State would contend trial process, jury verdict, and available appeals preserved any trial‑level objections; evidentiary sufficiency and admissibility issues were for the trial/appeals process	Claim asserted as constitutional violation and basis for habeas relief; no final disposition included in this petition

Key Cases Cited

Ex parte Seidel, 39 S.W.3d 221 (Tex. Crim. App. 2001) (lack of jurisdiction renders a judgment void and always subject to collateral attack)
Ex parte Drake, 883 S.W.2d 213 (Tex. Crim. App. 1994) (post‑conviction habeas available when trial court lacked jurisdiction and judgment is void)
Bender v. State, 353 S.W.2d 39 (Tex. Crim. App. 1962) (complaint not sworn by affiant is fatally defective and cannot support information)
Davis v. State, 503 S.W.2d 241 (Tex. Crim. App. 1974) (information based on fatally defective complaint is void; conviction on such information is void)
State v. Edwards, 808 S.W.2d 662 (Tex. App.—Tyler 1991) (fundamentally defective information is void and will not invoke court jurisdiction)

(Notes: This document is a pro se habeas petition setting forth jurisdictional, evidentiary, and due‑process claims and requesting vacatur of the judgment and immediate release. The excerpted file does not contain a final ruling by the Court of Criminal Appeals.)