Nicholas Davell Amos v. State, 05-14-00978-CR

Nicholas Davell Amos pleaded guilty (bench trial waiver) to six offenses across six causes: fraudulent use/possession of identifying information of an elderly person; multiple counts of forgery by check/forgery of a financial instrument (including offenses involving an elderly person); and tampering with a governmental record.
He also pleaded true to two enhancement paragraphs in each indictment; the trial court assessed punishment ranging from 10 to 25 years’ imprisonment depending on the offense.
The indictments were returned by a grand jury impaneled by the 195th Judicial District Court, but the cases were filed and tried in the 291st Judicial District Court in Dallas County.
Amos challenged the court’s jurisdiction, arguing the cases were not transferred from the 195th to the 291st Judicial District Court.
He also argued the evidence was insufficient to support convictions because his signed judicial confessions/stipulations of evidence were not marked as exhibits and thus allegedly did not comply with Tex. Code Crim. Proc. art. 1.15.
The trial court admitted Amos’s signed judicial confessions, stipulations of evidence, and his sworn testimony; the appellate court considered those materials in reviewing the Article 1.15 sufficiency question.

Issue	Plaintiff's Argument (Amos)	Defendant's Argument (State)	Held
Whether the trial court lacked jurisdiction because indictments returned by a grand jury impaneled by the 195th were not transferred to the 291st	Cases were presented to/handled by the 195th and no transfer order moved them to the 291st, so the 291st lacked jurisdiction	The 291st had jurisdiction because the indictments were filed in that court; no transfer order was necessary	Court held the 291st had jurisdiction; issue overruled
Whether evidence was sufficient under Art. 1.15 to support guilty pleas (judicial confessions not marked as exhibits)	Judicial confessions/stipulations were not admitted as exhibits, so insufficient evidence supported guilty pleas	Judicial confessions and sworn testimony were admitted without objection and embraced the elements, satisfying Art. 1.15	Court held evidence was sufficient; issue overruled

Ex parte Edone, 740 S.W.2d 446 (Tex. Crim. App. 1987) (grand jury as arm of the court and its role in indictments)
Hultin v. State, 351 S.W.2d 248 (Tex. Crim. App. 1961) (indictment filing in a court with competent jurisdiction)
Bourque v. State, 156 S.W.3d 675 (Tex. App.—Dallas 2005) (grand jury impaneling court need not receive all returned cases)
Dinnery v. State, 592 S.W.2d 343 (Tex. Crim. App.) (judicial confession sufficient to meet Article 1.15 requirements)
Stone v. State, 919 S.W.2d 424 (Tex. Crim. App. 1996) (evidence must embrace every element to support a guilty plea)