Michael Singleton v. State, 01-16-00058-CR

Michael Singleton was indicted (Oct 2014) for failure to register as a sex offender; a jury found him guilty and he was sentenced to 40 years.
During voir dire, counsel asked which jurors believed Singleton had a prior sexual-offense conviction requiring registration; multiple jurors initially answered yes, some citing the indictment.
The trial judge instructed the venire on the presumption of innocence and that the State must prove prior conviction; several jurors said they changed their views, one remained convinced.
Defense moved to strike the entire panel as tainted; the court struck several jurors for cause and overruled other objections; defense did not request extra peremptory strikes or identify an objectionable seated juror after exhausting peremptories.
On appeal Singleton argued the court erred in denying dismissal of the panel for bias, violating statutory and constitutional rights to an impartial jury.
The Court of Appeals affirmed, holding Singleton waived his complaint by failing to preserve error and, alternatively, the trial court did not abuse its discretion in assessing juror bias.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court erred by refusing to dismiss/strike the jury panel for bias	Singleton: many jurors initially believed he had a prior conviction based on the indictment, so panel was tainted	State: jurors were instructed, several changed answers, and defense failed to preserve error by not requesting additional peremptory strikes or identifying an objectionable seated juror	Affirmed — error waived for failure to preserve; trial court did not abuse discretion in assessing bias

State v. Morales, 253 S.W.3d 686 (Tex. Crim. App.) (Sixth Amendment right to impartial jury may be waived)
Jones v. State, 982 S.W.2d 386 (Tex. Crim. App.) (Texas constitutional impartial-jury protection aligns with Sixth Amendment)
Johnson v. State, 43 S.W.3d 1 (Tex. Crim. App.) (procedural requirements to preserve error on denial of challenge for cause)
Davis v. State, 329 S.W.3d 798 (Tex. Crim. App.) (standard of review for challenge-for-cause rulings; deference to trial judge)
Feldman v. State, 71 S.W.3d 738 (Tex. Crim. App.) (review of challenge-for-cause under entire record)
Gardner v. State, 306 S.W.3d 274 (Tex. Crim. App.) (deference when juror answers vacillating or unclear)
Castillo v. State, 913 S.W.2d 529 (Tex. Crim. App.) (burden on proponent to show juror understood law and could not follow it)
Hernandez v. State, 757 S.W.2d 744 (Tex. Crim. App.) (burden to show challenge for cause proper)