Morrison, Jared, WR-83,021-01

Morrison, pro se, filed a Motion to Object to the Trial Court's Findings of Fact and Conclusions of Law seeking review of post-conviction habeas corpus issues.
District court findings dated March 6, 2015 relied on affidavits from Morrison’s prior attorneys (David Rogers and Rodion Cantacuzene) and were challenged as untrue by Morrison.
Morrison submitted Exhibits N–S and moved to disqualify Rogers’ affidavit and to obtain a live evidentiary hearing, arguing the findings were one-sided.
Morrison argues Fleming v. State (Tex Crim. 2014) is distinguishable and that 22.011’s mental-state element should modify “of a child,” making the statute constitutionally valid under proper statutory construction.
He asserts the statute’s application to 14–16 year olds with First Amendment concerns and seeks relief via habeas corpus, including grounds alleging ineffective assistance and procedural violations.
The filing includes an unsworn declaration and a certificate of service indicating service on the Clerk, State, and Morrison’s address.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 22.011 is constitutional under proper statutory construction.	Morrison contends CMS must modify 'of a child' and that strict liability is unconstitutional.	Fleming validates the strict liability interpretation to protect children without requiring age-specific mens rea.	Undetermined in these filings; Morrison argues distinction but Fleming largely controls.
Whether the district court’s reliance on Fleming is misplaced and merits live evidentiary resolution.	Morrison seeks an evidentiary hearing to address disqualified affidavits and unresolved issues.	District court relied on affidavits; Morrison’s motion to disqualify raises questions.	Remains for decision; Morrison requests hearing if grounds differ.
Whether Morrison’s claims of ineffective assistance of counsel and 11.072 procedures were properly preserved and warranted relief.	Morrison asserts IAC and improper writ procedures impeded relief.	Findings rely on affidavits; procedural issues not yet resolved.	Not resolved in the Findings; Morrison seeks relief under Grounds 8-13.

Fleming v. State, 441 S.W.3d 252 (Tex. Crim. 2014) (discusses mens rea and age in 22.011; rational basis approach criticized by Morrison)
Vasquez v. State, 622 S.W.2d 864 (Tex Crim. 1981) (pre-1983 strict liability framework referenced by Morrison)
Liparota v. United States, 471 U.S. 419 (U.S. 1985) (addresses mental element in statutes (CMS) and notice concerns)
Staples v. United States, …, (U.S. 1994) (ties to mental element requirements in statutory schemes)
X-Citement Video v. United States, 509 U.S. 161 (U.S. 1993) (addresses mens rea and legality in sexual offense context)
Griswold v. Connecticut, 381 U.S. 479 (U.S. 1965) (First Amendment foundational privacy rights cited by Morrison)
Eisenstadt v. Baird, 405 U.S. 438 (U.S. 1972) (extends privacy and intimate decisions; supports First Amendment analysis)
Lawrence v. Texas, 539 U.S. 558 (U.S. 2003) (protects intimate conduct; relevance to First Amendment analysis)
Planned Parenthood of Central Missouri v. Danforth, 428 U.S. 52 (U.S. 1976) (references abortion-related constitutional standards (context for privacy and liberty))
Dombrowski v. Pfister, 380 U.S. 479 (U.S. 1965) (civil rights and liberty issues relevant to constitutional analysis)
Bigelow v. Virginia, 421 U.S. 809 (U.S. 1975) (First Amendment protection for expressive conduct)
Zubia v. State, 998 S.W.2d 226 (Tex Crim. 1999) (discusses statutory interpretation and age-related defenses)