Paolilla v. State, 342 S.W.3d 783

Appellant Christine Paolilla was convicted of capital murder for the July 18, 2003 killings in Clear Lake; she was seventeen, so death eligibility did not apply and she received life imprisonment.
Authorities arrested Paolilla in San Antonio in July 2006 after Crime Stoppers linked the homicides to her and her then-boyfriend Snider; a warrant was executed at a hotel.
Paolilla gave three recorded interrogations (San Antonio and Houston) in which she initially denied involvement but later admitted to being present inside the house while Snider fired.
At a suppression hearing, Paolilla argued her statements were involuntary due to heroin withdrawal and drug treatments; the trial court denied suppression.
The State’s witnesses testified Paolilla appeared lucid and coherent during interviews, and expert Dr. Glass’s volatility about withdrawal was not credited by the court.
The jury convicted Paolilla after the trial court gave standard law-of-parties instructions; she received a mandatory life sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile life-without-parole-like sentence is cruel and unusual.	Paolilla argues the mandatory life sentence is disproportionate for a juvenile.	State contends no constitutional violation; Meadoux and precedent permit the sentence.	Issue overruled; no cruel/unusual punishment.
Whether the trial court abused its discretion by denying mistrial after improper closing.	Paolilla asserts prosecutorial argument outside the record warrants mistrial.	State argues curative instruction rendered any error harmless.	Issue overruled; no abuse of discretion.
Whether the trial court properly denied suppression of Paolilla's three statements.	Waiver was involuntary due to withdrawal and drug treatment impairing capacity.	Waivers were voluntary; officers credibly testified she was lucid.	Issue overruled; statements admitted.
Whether Townsend v. Sain was misapplied to suppress the statements.	Townsend requires suppression due to coherency under drug influence.	No coercion or lack of free will; Townsend not violated.	Issue overruled; Townsend not violated.
Whether the court erred in excluding/limiting Dr. Glass’s opinions on voluntariness.	Daubert-like concerns; Glass’s withdrawal testimony should have been credited.	Court properly credited officers and found voluntary waiver.	Issue overruled; expert rejected for credibility.

Graham v. Florida, 560 U.S. 48 (U.S. 2010) (juvenile life without parole for non-homicide offenses prohibited)
Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juvenile capital punishment prohibited)
Meadoux v. State, 325 S.W.3d 189 (Tex. Crim. App. 2010) (measures factors for juvenile capital offender; upholds life-without-parole precedent)
Laird v. State, 933 S.W.2d 707 (Tex. App.—Houston [14th Dist.] 1996) (mandatory sentence for capital murder sustained; youth mitigation acknowledged)
Kennedy v. Louisiana, 554 U.S. 407 (U.S. 2008) (considers national consensus in Eighth Amendment analyses)